Virtual Currency Report, published by Perkins Coie LLP, focuses on legal and regulatory developments affecting virtual currencies, digital assets, and blockchain technology. The blog covers topics such as regulatory approvals and enforcement actions related to cryptocurrency products, including exchange-traded funds and digital asset securities. It also addresses updates from financial regulators like the SEC, NYDFS, and the Federal Reserve concerning compliance, risk management, and supervisory programs for banks and fintech firms involved in crypto activities. The blog provides insights on policy changes, self-certification processes for digital assets, and legal implications of emerging financial technologies and partnerships in the crypto space.
Part 1: Commentary on the Significance of the Guidance for the Industry
On March 24, 2020, the U.S. Commodity Futures Trading Commission (CFTC) finalized long-awaited interpretive guidance regarding what constitutes the “actual delivery” of a digital asset in the context…
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In the midst of the COVID-19 pandemic, the financial markets have experienced significant volatility. During the course of this volatility, exchanges have halted trading multiple times after declines in trading trigged circuit breakers. In addition, trading floors are transitioning to…
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On March 9, 2020, FINRA released Regulatory Notice 20-08 (the “Regulatory Notice”) providing guidance and limited relief to its member broker-dealers during the COVID-19 pandemic. In particular, the Regulatory Notice requests that broker-dealers evaluate their compliance with FINRA Rule 4370…
On March 10, the New York State Department of Financial Services (DFS) issued guidance and a request for assurance to financial institutions engaged in virtual currency business activity in New York. The request requires regulated virtual currency businesses to prepare…
