Our client alert discusses the SEC Division of Examinations list of priorities for 2023, which provides a roadmap for firms to better understand where the Division will take its examination efforts over the coming months.
Our client alert discusses the SEC Division of Examinations list of priorities for 2023, which provides a roadmap for firms to better understand where the Division will take its examination efforts over the coming months.
Our recent client alert discusses the SEC complaint against three individuals alleging insider trading of digital assets via a scheme to trade ahead of multiple announcements regarding crypto assets being made available on a United States-based digital asset exchange at which one individual was a former product manager.
Our recent client alert discusses the SEC’s “Reg Flex” agenda for rulemaking, which provides a glimpse into how the agency will prioritize its resources over the coming six months from a policy and rulemaking standpoint.
The SEC recently proposed rules that would greatly expand the Exchange Act definition of “dealer” and essentially kill the existing dealer/trader distinction long-recognized by the SEC. The likely outcome is that most proprietary trading firms will need to register with the SEC as dealers and become members of FINRA or…
Our recent client alert discusses President Biden’s Executive Order Ensuring Responsible Development of Digital Assets.
Here is a link to our client alert addressing the SEC’s proposed change to the “exchange” definition, including introduction of the new term “communication protocol system.” There were zero references to crypto, blockchain, DeFi, or distributed ledger technology in the 654-page proposal. Nevertheless, the proposal makes clear that it applies…
On March 15, 2021, ISDA published the ISDA 2021 Security-Based Swaps (SBS) Top-Up Protocol (the SBS Top-Up Protocol). The SBS Top-Up Protocol enables SBS dealers (SBSDs) and other market participants to comply with certain SBS rules implemented by the SEC under Title VII of the Dodd–Frank Wall Street Reform and…
On March 17, 2021, Acting CFTC Chairman Rostin Behnam announced that the derivatives regulator had established a new interdivisional group called the Climate Risk Unit or the “CRU” to focus on the derivatives markets’ role in addressing climate-related risk and transitioning to a low-carbon/net-zero economy. The CRU (sounds like an…