FINRA Rules and the arbitration landscape are constantly changing. FINRA members and practitioners must stay sensitive to the issues and new developments to reduce the chances of surprise awards and enforcement actions.
To date, conscientious traders of digital assets and cryptocurrencies have mostly sought regulatory refuge under the quilt of state money transmission laws.
On March 7, 2018, the Securities and Exchange Commission’s Enforcement Division and its Trading & Markets Division issued a joint “Statement on Potentially Unlawful Online Platforms for Trading Digital Assets.” The release appeared to be the strongest signal yet of a broadening of the SEC’s enforcement and regulatory interest beyond its focus over the last year on the need for certain coin offerings to be registered or to qualify for an exemption as private placements.
Greater Richmond Compliance Roundtable, Speaker, "Cybersecurity and Data Protection for Compliance Professionals"
Issuers and others involved in offerings of crypto asset securities, such as "ICO"s, must be alert to the potential application of SEC Regulation M.