National Futures Association Repeals Virtual Currency and Virtual Currency Derivative Disclosure Requirements, Expands Others, October 20, 2025
SEC Division of Investment Management No-Action Letter Concerning Custody Provisions With Respect to the Placement and Maintenance of Crypto Assets and Related Cash and/or Cash Equivalents, September 30, 2025
CFTC Launches Tokenized Collateral and Stablecoins Initiative, September 23, 2025
SEC-CFTC Joint Staff Statement on Exchange Listing of Certain Spot Crypto Asset Products September 2, 2025
Back-to-School Checklist for Digital Asset Business Leaders and Lawyers, September 2025
SEC, Division of Corporation Finance Statement on Certain Liquid Staking Activities, August 5, 2025
SEC, Commissioner Hester Peirce Statement: Staking Sequel – Comments on Division of Corporation Finance’s Statement on Certain Liquid Staking Activities, August 5, 2025
SEC, Commissioner Caroline Crenshaw Statement: Response to Staff Statement on Certain Liquid Staking Activities: Caveat Liquid Staker, August 5, 2025
CFTC, Acting Chairman Pham Launches Listed Spot Crypto Trading Initiative, August 4, 2025
Acting Chairman Pham Announces CFTC Crypto Sprint, August 1, 2025
SEC, Chairman Atkins Speech: American Leadership in the Digital Finance Revolution (Project Crypto), July 31, 2025
President’s Working Group on Digital Asset Markets Issues Report, July 30, 2025
SEC Chairman Paul S. Atkins Statement on President Trump Signing the GENIUS Act into Law, July 18, 2025
SEC Commissioner Hester M. Peirce, Smart Start: Statement on the GENIUS Act, July 18, 2025
SEC Chairman Paul S. Atkins Statement on Passage of the GENIUS Act by the House of Representatives, July 17, 2025
SEC Staff Input Eases Path For Broker-Dealer Crypto Activities, June 3, 2025
SEC Division of Corporation Finance Statement on Certain Protocol Staking Activities, May 29, 2025
SEC Commissioner Caroline Crenshaw Response to Staff Statement on Protocol Staking Activities: Stake it Till You Make It?, May 29, 2025
SEC Commissioner Hester Peirce, Providing Security is not a “Security” – Division of Corporation Finance’s Statement on Protocol Staking, May 29, 2025
SEC Paves the Way for Crypto Asset Activities by Broker-Dealers and Transfer Agents, May 19, 2025
Justice Department Issues Memorandum on Digital Asset Enforcement Priorities, April 7, 2025
CFTC Staff Withdraws Advisory on Virtual Currency Derivative Product Listings, March 28, 2025
CFTC Staff Withdraws Advisory on Review of Risks Related to Clearing Digital Assets, March 28, 2025
SEC Staff Statement on Certain Proof-of-Work Mining Activities, March 20, 2025
SEC Commissioner Crenshaw Statement on Proof-of-Work Mining Guidance, March 20, 2025
Sidley’s Kate Lashley in Web.3 Discussion With CFTC Commissioner Mersinger, March 5, 2025
SEC Announces Dismissal of Civil Enforcement Action Against Coinbase, February 27, 2025
Getting Back on Base: Statement of Commissioner Hester M. Peirce on the Dismissal of the Civil Enforcement Action Against Coinbase, February 27, 2025
SEC Staff Statement on Meme Coins, February 27, 2025
Engage With the U.S. SEC’s Crypto Task Force and Shape the Future of Crypto Regulation, February 24, 2025
A Roadmap to Engagement With the U.S. SEC’s New Crypto Task Force, February 6, 2025
With New Technologies Come New Risks: FINRA Issues 2025 Regulatory Oversight Report, February 4, 2025
SEC Staff Accounting Bulletin No. 122: Rescinding SAB 121 (Accounting for Obligations to Safeguard Crypto-Assets an Entity Holds for its Platform Users), January 23, 2025
Executive Order: Strengthening American Leadership in Digital Financial Technology, January 23, 2025
SEC Crypto 2.0: Acting Chairman Uyeda Announces Formation of New Crypto Task Force, January 21, 2025
SEC Charges Software Company for Unregistered Offers and Sales of Securities and Operating as an Unregistered Broker, June 28, 2024
D.C. District Court Dismisses Certain “Investment Contract” Claims Against Binance; Bulk of SEC’s Case to Proceed, June 28, 2024
New York DFS Issues New Guidance Regarding Virtual Currency Customer Service Requirements, May 30, 2024
SEC Approves Listing and Trading of Spot Ether ETFS, May 23, 2024
DOJ Charges Hackers in Ethereum MEV Exploit, May 15, 2024
CFTC Issues First-of-its-Kind Order Against Crypto Prime Brokerage Firm for Providing U.S. Customers Access to Digital Asset Trading Platforms, May 13, 202
SEC Charges Trading Platform with Operating as an Unregistered Dealer, March 5, 2024
Dissenting Statement on ShapeShift AG, March 5, 2024
SEC Adopts Rules to Include Certain Significant Market Participants as “Dealers” or “Government Securities Dealers”, February 6, 2024
FINRA Provides Update on Targeted Exam: Crypto Asset Communications, January 23, 2024
SEC Approves Listing and Trading of Spot Bitcoin ETPs, January 10, 2024
FINRA 2024 Annual Regulatory Oversight Report Chapter on Crypto Assets, January 9, 2024
ISDA Publishes Tokenized Collateral Model Provisions for ISDA 2016 Credit Support Annexes, December 20, 2023
Press Release: FinCEN Proposes New Regulation to Enhance Transparency in Convertible Virtual Currency Mixing, October 19, 2023
Legislation: California Enacts Digital Financial Asset Licensing Law, October 13, 2023
Press Release: NY DFS Proposes Revised Token Listing Guidance and Updates Pre-approved "Greenlist", September 18, 2023
CFTC Enforcement: CFTC Announces Enforcement Actions Against Three DeFi Protocols, Sept. 7, 2023
Opinion: SDNY Dismisses Securities Law Claims Against DeFi Protocol, Aug. 30, 2023
Opinion: D.C. Court of Appeals Vacates SEC Order Denying Spot Bitcoin ETF, Aug. 29, 2023
Statement of CFTC Division of Enforcement Director Ian McGinley on the Ooki DAO Litigation Victory, June 9, 2023
SEC Enforcement: Coinbase Charged with Operating as an Unregistered Securities Exchange, Broker, and Clearing Agency, Jun. 6, 2023
Sidley Update: SEC Shines Spotlight on Crypto Asset Securities Trading Systems and DeFi in Reopening Comments on Reg ATS Proposal, April 26, 2023
CFTC Enforcement: Binance Charged with Operating Illegal Derivatives Exchange and Evading US Law, Mar. 27, 2023
Sidley Update: SEC Proposes Sweeping Revisions to Advisers Act Custody Rule, February 21, 2023
“Request for Information; Digital Assets Research and Development,” The Federal Register, January 26, 2023
Press Release: “Treasury Announces Two Enforcement Actions for over $24M and $29M Against Virtual Currency Exchange Bittrex, Inc.,” October 11, 2022
Sidley Update: Doubts about DAOs: Novel CFTC Enforcement Case Targets Decentralized Finance Community, October 6, 2022
Press Release: “Financial Stability Oversight Council Releases Report on Digital Asset Financial Stability Risks and Regulation,” U.S. Department of Treasury, October 3, 2022
SEC Enforcement: “SEC Charges Kim Kardashian for Unlawfully Touting Crypto Security,” October 3, 2022
SEC Enforcement: “SEC Charges The Hydrogen Technology Corp. and its Former CEO for Market Manipulation of Crypto Asset Securities,” September 28, 2022
CFTC Enforcement: “CFTC Imposes $250,000 Penalty Against bZeroX, LLC and Its Founders and Charges Successor Ooki DAO for Offering Illegal, Off-Exchange Digital-Asset Trading, Registration Violations, and Failing to Comply with Bank Secrecy Act,” September 22, 2022
Press Release: “Treasury Seeks Public Input on Illicit Finance, National Security Risks Posed by Digital Assets,” U.S. Department of Treasury, September 19, 2022
Press Release: “Statement from Secretary of the Treasury Janet L. Yellen on the Release of Reports on Digital Assets,” U.S. Department of Treasury, September 16, 2022
Press Release: “Justice Department Announces Report on Digital Assets and Launches Nationwide Network,” U.S. Department of Justice, September 16, 2022
Press Release: “FDIC and Federal Reserve Issue Letter Demanding Voyager Digital Cease and Desist from Making False or Misleading Representations of Deposit Insurance Status,” The Federal Deposit Insurance Corporation, July 28, 2022
Sidley Update: Responsible Financial Innovation Act: A Proposed Digital Asset Regulation With Implications for Products and Regulatory Frameworks, June 9, 2022
Sidley Update: FinCEN Seeks Public Comments on a “No-Action” Letter Process, June 9, 2022
Sidley Update: SDNY Files First Indictment Related to Insider Trading of NFTs While SEC Enforcement Expands Focus on Digital Assets Broadly, June 8, 2022
Press Release: “DFS Superintendent Adrienne A. Harris Issues New Guidance to Prevent and Manage Suspicious Activities in the Virtual Currency Industry,” New York State Department of Financial Services, April 28, 2022
Sidley Update: The SEC Has Crypto in Its Crosshairs (Again), April 8, 2022
Sidley Update: SEC Announces 2022 Examination Priorities: Private Funds, ESG, Retail, Cyber, Digital Assets Top the List, April 6, 2022
Sidley Update: The CFPB in the Biden Administration — The Newest Federal Competition Enforcer, March 24, 2022
Sidley Update: Executive Order on Ensuring Responsible Innovation in Digital Assets, March 15, 2022
Sidley Update: Recent DOL Guidance Raises Concerns About Cryptocurrency Investment Options in 401(k) Plans, March 14, 2022
Sidley Update: SEC Targets Digital Asset Lending in Enforcement Action and Investor Bulletin, February 18, 2022
Sidley Update: U.S. Treasury Study of Money Laundering Risks in the Art World Focuses on NFTs, February 11, 2022
Sidley Update: FinCEN Proposed Rule Will Require Many Domestic and Foreign Entities to Report Beneficial Ownership Information to the U.S. Government, December 13, 2021
Sidley Update: Five Key Considerations Regarding New U.S. Sanctions to Address Ransomware Threats, September 23, 2021
Virtual Currency Regulation Review: USA Chapter, September 2021
Blockchain and Digital Assets, from PLI Treatises: FinTech, RegTech, and the Financial Services Industry, July, 2021
Sidley Update: Enhanced Focus on Digital Asset Intermediaries by SEC, Congress, and State Securities Regulators, July 27, 2021
Sidley Update: FinCEN Issues Government-Wide Priorities for Anti-Money Laundering and Counter-Terrorist Financing, July 1, 2021
Sidley Update: El Salvador’s Adoption of Bitcoin as Legal Tender May Bring Bitcoin Activity Within Scope of Money Transmitter Laws in More States, June 11, 2021
Video: Energy Infrastructure Council Investor Conference May 2021: New Financing Techniques Using Digital and Blockchain Solutions & Platforms, May 2021
Sidley Webinar: DeFi with DARLA: What You Need to Know About DeFi, April 14, 2021
Sidley Update: U.S. Office of Foreign Assets Control Enforcement Actions Highlight Sanctions-Related Risks of Transacting in Digital Currencies, March 11, 2021
Sidley Update: SEC’s Division of Examinations Publishes Risk Alert and Compliance Guidance for Digital Asset Securities Activities, March 3, 2021
Press Release: “OCC Conditionally Approves Conversion of Anchorage Digital Bank,” Office of the Comptroller of the Currency, January 13, 2021
Sidley Update: Congress Rings in the New Year With Substantial Changes to Anti-Money Laundering Laws, January 5, 2021
Enforcement Release: “OFAC Enters Into $98,830 Settlement with BitGo, Inc. for Apparent Violations of Multiple Sanctions Programs Related to Digital Currency Transactions,” Department of the Treasury, December 30, 2020
Sidley Update: Digital Asset Securities Custody: U.S. SEC Issues Broker-Dealers Enforcement Relief and Requests Industry Comment, December 28, 2020
Sidley Webinar: FinTech Enforcement Priorities: Protecting Investors, the Economy, and Public Safety, December 15, 2020
Article: “DEFI: The New Paradigm,” Forbes, November 30, 2020
SEC Statement: Staff Statement on WY Division of Banking’s “NAL on Custody of Digital Assets and Qualified Custodian Status,” November 9, 2020
The Virtual Currency Regulation Review: United States Chapter, November, 2020
Sidley Update: Office of Foreign Assets Control: Making or Facilitating Ransomware Payments May Violate U.S. Sanctions, October 7, 2020
Sidley Update: SEC Issues No-Action Letter for Certain Alternative Trading Systems Trading Digital Asset Securities, September 29, 2020
Public Statement: SEC FinHub Staff Statement on OCC Interpretation, September 21, 2020
Sidley Update: FinCEN Seeks Input on Proposed Clarifications of Anti-Money Laundering Program Requirements, September 21, 2020
Sidley Update: Joint Statement Seeks to Provide Additional Guidance Regarding Customer Due Diligence Expectations for Politically Exposed Persons, August 25, 2020
Article: “Big Data: Legal and Compliance Considerations for Investment Managers,” Investment Adviser Regulation: A Step-by-Step Guide to Compliance and the Law (Third Edition), August 23, 2020
Sidley Update: FinCEN Identifies Key Factors in Evaluating Potential or Actual BSA Violations for Enforcement Actions, August 21, 2020
Sidley Webinar: A Peek Behind the Curtain: Changes at the SEC and the Implications for Blockchain, August 6, 2020
Sidley Update: OCC Confirms the Authority of National Banks to Provide Cryptocurrency Custody Services, July 27, 2020
Letter: “Authority of a National Bank to Provide Cryptocurrency Custody Services for Customers,” Office of the Comptroller of the Currency, July 22, 2020
Sidley Update: NYDFS Announces a Series of Virtual Currency Initiatives, July 6, 2020
Press Release: “DFS Superintendent Lacewell Launches Series of Virtual Currency Initiatives,” Department of Financial Services, June 24, 2020
Blockchain and Digital Assets, from PLI Treatises: Broker-Dealer Regulation and Investment Adviser Regulations 2020, May, 2020
The Sidley Podcast, “Blockchain: Poised to Transform Business,” March 2020
SEC Bitcoin ETF Disapproval Release No. 34-88284, February 26, 2020
Sidley Update: SEC Commissioner Peirce Proposes Blockchain Token Safe Harbor, February 13, 2020
Article: “Implications for Blockchain in Energy Markets,” Futures and Derivatives Law Report, December, 2019
International Virtual Currency Regulation Review: USA Chapter, November, 2019
Paxos No-action Letter, October 28, 2019
Article: “Beyond Howey: Is Stability a Security? The Evolving Digital Asset Framework,” Westlaw, October 25, 2019
Sidley Update: Conference of State Bank Supervisors Releases Draft Model MSB Law, October 17, 2019
Sidley Update: U.S. Financial Regulators Clarify Oversight of AML/CFT Obligations in Connection with Digital Asset Activities, October 16, 2019
Leaders of CFTC, FinCEN and SEC Issue Joint Statement on Activities Involving Digital Assets, October 11, 2019
Video of CFTC Chairman Heath Tarbert’s “Ether is a Commodity” Interview, Yahoo Finance All Markets Summit, October 10, 2019
Sidley Update: Digital Asset Securities: Joint SEC and FINRA Statement Aimed at Broker-Dealer Custody, July 11, 2019
SEC and FINRA “Joint Staff Statement on Broker-Dealer Custody of Digital Asset Securities,” July 8, 2019
Sidley Update: Financial Action Task Force Guidance Regarding Digital Asset Exchanges, ICOs, DApps, Wallets and More, July 1, 2019
Sidley Update: Financial Crimes Enforcement Network Guidance Regarding Convertible Virtual Currencies, Wallets, ICOs, DApps and More, May 15, 2019
Sidley White Paper: Custody of Digital Asset Securities: A Proposal to Address Open Questions for Broker-Dealers Under the SEC’s Customer Protection Rule, March 18, 2019
SEC Division of Investment Management Letter: Engaging on Non-DVP Custodial Practices and Digital Assets, March 12, 2019
ISDA, Legal Guidelines for Smart Derivatives Contracts: The ISDA Master Agreement, February 19, 2019
ISDA, Legal Guidelines for Smart Derivatives Contracts: Introduction, January 30, 2019
LabCFTC: A Primer on Smart Contracts, November 27, 2018
NFA Interpretive Notice on Disclosure Requirements for NFA Members Engaging in Virtual Currency Activities—9073 Board of Directors, May 17, 2018; effective October 31, 2018
CFTC Staff Advisory on Virtual Currency Derivative Product Listings No. 18-14, May 21, 2018
Dalia Blass SEC Staff Letter: Engaging on Fund Innovation and Cryptocurrency-related Holdings, January 18, 2018
CFTC Proposed Interpretation of “Actual Delivery” for Retail Commodity Transaction in Virtual Currency, Federal Register, Vol. 82, No. 243, Proposed Rules, December 20, 2017
