The staff of the SEC’s Division of Trading and Markets issued a statement explaining how non-custodial crypto wallet providers may offer services and receive fees without broker-dealer registration.
Virtual Currencies, Digital Assets & the Law
Erika Cabo focuses her practice on regulation, structuring, and compliance of, and transactions in, blockchain and digital assets, derivatives and complex structured products. She represents a diverse range of clients, including global blockchain technology companies, cryptocurrency exchanges, token sellers, cryptocurrency funds, broker-dealers, major global investment banks and financial institutions. Erika advises on tokenization of real-world assets, blockchain-based capital markets transactions, blockchain token sales, and trading and investment in digital assets.
Erika engages with regulators and policymakers on behalf of clients, including representing blockchain platforms before the SEC’s Crypto Task Force and drafting comment letters on proposed SEC rules. She has represented technology companies in advanced policy initiatives such as the CLARITY Act and market structure bills, advocating for clear regulatory definitions and safe harbor frameworks to support responsible innovation in the digital asset space.
Erika counsels financial institutions, blockchain platforms, centralized and decentralized digital asset exchanges and technology companies on securities and commodities issues, custody rule requirements, broker-dealer matters and cross-border regulatory issues. She structures deals and negotiates U.S. and cross-border agreements involving digital assets and complex financial products and regularly helps clients navigate evolving federal and state securities and commodities laws and regulations.
In her derivatives practice, Erika advises on all aspects of derivatives and structured products transactions across the U.S. and Latin America, including regulatory strategy, compliance, negotiation, structuring and documentation. Erika advises both regulated entities and end users on Dodd-Frank Act and Commodity Exchange Act regulation and compliance, and on the structuring of innovative hedging, trading, and risk management solutions.
In a previous role, Erika practiced in the New York office of a global law firm, where she represented buy-side and sell-side financial institutions, corporates and technology companies in the U.S. and Latin America in derivatives trading, documentation, and regulatory matters. She also counseled technology companies on securities laws in the firm’s blockchain and digital assets practice. She is fluent in Spanish.
The staff of the SEC’s Division of Trading and Markets issued a statement explaining how non-custodial crypto wallet providers may offer services and receive fees without broker-dealer registration.
On March 17, 2026, the U.S. Securities and Exchange Commission issued an interpretive release addressing the application of the federal securities laws to crypto assets and related transactions. The Commodity Futures Trading Commission joined the interpretation and indicated it will administer the Commodity Exchange Act consistent with the SEC’s approach, reflecting a coordinated regulatory position across the two agencies.
Continue Reading SEC Clarifies Status of Crypto Assets Under Federal Securities Laws, Signals Potential Exemptive and Safe Harbor Framework
The U.S. Securities and Exchange Commission staff issued a joint statement on Jan. 28, 2026, providing greater clarity on the application of the federal securities laws to the category of crypto assets commonly referred to as tokenized securities.…
Continue Reading SEC Issues Guidance on Applying Federal Securities Laws to Tokenized Securities