Trevor Dodge

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Trevor Dodge earned a J.D. from NYU School of Law, where he was a staff editor for the Journal of Intellectual Property & Entertainment Law and president of the Student Lawyer Athletic Program. While at NYU, he worked as a legal intern for the World Bank Group in New Delhi and assisted the New York State Department of Financial Services in implementing a regulatory framework for firms dealing in Bitcoin and similar virtual currencies.

Prior to law school, Trevor served as a Fulbright scholar in Si Satchanalai, Thailand.

Latest Articles

On April 11, Blockstack Token LLC (“Blockstack”) filed a preliminary offering circular with the SEC for a $50 million token offering under Regulation A of the Securities Act. The offering circular is now under review with the SEC and must be qualified (i.e., cleared) by the SEC before sales of Blockstack’s tokens (“Stacks Tokens”) can be effectuated under the program. Blockstack’s offering circular is notable because it treats the Stacks Tokens as securities today but…
The Securities and Exchange Commission (“SEC”) recently issued highly anticipated guidance to assist market participants in determining whether a digital asset is offered and sold as a security. On April 3, 2019, the SEC’s Strategic Hub for Innovation and Financial Technology published an analytical framework for evaluating whether the offer and sale of a digital asset is an “investment contract” and therefore a security subject to regulation under the federal securities laws.  On the same…
On October 18, the SEC announced the launch of a new Strategic Hub for Innovation and Financial Technology (the “FinHub”). The FinHub provides an online portal for market participants to engage with the SEC on a range of FinTech-related issues, including distributed ledger technology and digital assets. The FinHub contains a comprehensive repository of information relating to the SEC’s position on the issuance and transfer of blockchain-based digital assets, including links to key public statements…
At last week’s Yahoo! All Markets Summit in Palo Alto, SEC Division of Corporation Finance Director William Hinman delivered a speech sure to send shockwaves through the crypto world. Applying the Howey test (which sets forth the elements necessary for determining whether a transaction involves the offer or sale of an “investment contract” and thus, a security, under the federal securities laws) to cryptoasset transactions, Director Hinman concluded that: To determine whether a token sale…
On May 29, the SEC announced that it had secured injunctive relief halting an allegedly “ongoing fraud” involving an unregistered, non-exempt ICO that raised as much as $21 million in cryptoassets. The SEC’s complaint charges Titanium Blockchain Infrastructure Services, Inc., EHI Internetwork and Systems Management, Inc. and Michael Stollery, (collectively, the “Titanium defendants”) with fraud in connection with the purchase, offer or sale of securities under Sections 10 and 17 of the Securities Exchange Act…
When a smart contract coding vulnerability resulted in the Parity wallet “freeze” that compromised over $150 million worth of user funds, we discussed the pitfalls of unsecure code in the context of cryptoassets and the extent to which software developers might be held liable to their users for losses arising from mistakes in, or the exploitation of, the open source software they release into the world. On Thursday, yet another possible coding vulnerability emerged –…
Last month, SEC chairman Jay Clayton and CFTC chairman Christopher Giancarlo testified before the Senate Banking Committee on their agencies’ regulatory efforts with respect to cryptoassets and ICOs. The written testimonies of chairmen Clayton and Giancarlo, as well as their verbal statements at the hearing itself, shed light on various issues including:  how tokens might be categorized; the desirability of targeted legislative action to address jurisdictional gaps in the cryptoasset marketplace; coordination among regulators;…
The CFTC and SEC made numerous headlines Friday in their ongoing efforts to provide regulatory oversight of cryptocurrency markets. The CFTC announced the filing of two civil enforcement actions against allegedly fraudulent cryptocurrency-related investment schemes. The SEC’s Division of Investment Management, meanwhile, issued a letter raising concerns about registered investment companies’ (including ETFs’) investments in cryptocurrencies and cryptocurrency-related assets. And the SEC and CFTC issued a joint statement emphasizing their collective aim to root out…
The world’s first SEC-registered cryptocurrency exchange may be just around the corner. As detailed in their October 24 Form 8-K, Overstock.com subsidiary tZERO has entered into a joint venture with The Argon Group and RenGen LLC to launch a U.S. registered Alternative Trading System (“ATS”) for digital tokens. If successful, the tZERO ATS may represent a monumental development in the evolving landscape of blockchain-based fundraising by providing secondary market liquidity for ICO tokens affirmatively…
The SEC took two additional steps today in its regulation and oversight of the initial coin offering (“ICO”) and cryptocurrency markets. In the SEC’s latest action targeting an ICO, the SEC Enforcement Division’s new Cyber Unit intervened in an attempted ICO by Munchee, Inc., an online food review service with plans to build out its network on blockchain.  In its cease-and-desist order, the SEC found that the tokens offered by Munchee were securities, and…