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Overheard on the Block(chain)

Virtual Currencies, Digital Assets & the Law

Topics

Asset-backed Tokens

SEC Issues Guidance on Applying Federal Securities Laws to Tokenized Securities Nasdaq Proposes Rule Changes to Enable Trading of Tokenized Securities Federal Reserve and FDIC Withdraw Crypto-Asset Guidance for Banks; OCC Issues Clarification for Banks

Blockchain

SEC Staff Clarifies Broker-Dealer Registration Expectations for Non-Custodial Crypto Wallet Providers SEC Clarifies Status of Crypto Assets Under Federal Securities Laws, Signals Potential Exemptive and Safe Harbor Framework SEC Issues Guidance on Applying Federal Securities Laws to Tokenized Securities

California

California DFPI Issues Formal Rulemaking for Digital Financial Asset Regulation California Enacts Digital Assets Licensing Law California State Assembly Introduces Legislation to Establish Digital Financial Assets Law

Cryptocurrency

SEC Staff Clarifies Broker-Dealer Registration Expectations for Non-Custodial Crypto Wallet Providers SEC Issues Guidance on Applying Federal Securities Laws to Tokenized Securities CFTC Opens Door to Spot Crypto Trading on Regulated Exchanges

DeFi

Congress Overturns IRS Reporting Rules for DeFi Platforms SEC Clarifies Stance on Reserve-Backed Stablecoins 5 Trends to Watch: 2025 Futures & Derivatives

DOAs

Digital Assets Sector: What to Watch for in 2022

Economic sanctions

Fifth Circuit Rejects OFAC Sanction of Tornado Cash Crypto Code New Italian Rules for Virtual Asset Service Providers Crypto Exchange Bittrex Settles $53 Million in Fines with Treasury Department for Sanctions, Anti-Money-Laundering Violations

European Union

New Italian Rules for Virtual Asset Service Providers MICA Regulation: The EU Parliament’s Position on ‘Proof-of-Work’ Mechanism

Event

GT's Blockchain & Digital Assets Group Hosts 'The New Bermuda Triangle: Managing Risks in the Digital Age'

Exchange-traded products

SEC Approves In-Kind Creations and Redemptions for Crypto ETPs

FDIC

Federal Reserve, FDIC, and OCC Issue 2nd Joint Statement Highlighting Liquidity Risks to Banks Engaged in Crypto-Asset-Related Activities Federal Reserve, FDIC, and OCC Issue the First Joint Statement on Crypto-Asset Risks to Banking Organizations US Federal Banking Regulators Release Joint Statement on ‘Crypto-Asset Policy Sprint Initiative’

Featured

SEC Staff Clarifies Broker-Dealer Registration Expectations for Non-Custodial Crypto Wallet Providers The Rise of Digital Debt Securities in the Middle East SEC Clarifies Status of Crypto Assets Under Federal Securities Laws, Signals Potential Exemptive and Safe Harbor Framework

Federal Reserve System

Federal Reserve and FDIC Withdraw Crypto-Asset Guidance for Banks; OCC Issues Clarification for Banks Federal Reserve, FDIC, and OCC Issue 2nd Joint Statement Highlighting Liquidity Risks to Banks Engaged in Crypto-Asset-Related Activities Federal Reserve, FDIC, and OCC Issue the First Joint Statement on Crypto-Asset Risks to Banking Organizations

Financial Regulatory & Compliance

SEC Issues Guidance on Applying Federal Securities Laws to Tokenized Securities CFTC Opens Door to Spot Crypto Trading on Regulated Exchanges Nasdaq Proposes Rule Changes to Enable Trading of Tokenized Securities

Firm News

Greenberg Traurig Represents Riot in Acquisition of Block Mining GT's Blockchain & Digital Assets Group Hosts 'The New Bermuda Triangle: Managing Risks in the Digital Age'Greenberg Traurig’s Barbara A. Jones Named Law360 2020 MVP for Fintech

Florida

Florida Gov. Signs Bill that Defines ‘Virtual Currency’ and Eases Licensing Restrictions on Certain Virtual Currency Transactions in the State

GT Alert

The Rise of Digital Debt Securities in the Middle East SEC Clarifies Status of Crypto Assets Under Federal Securities Laws, Signals Potential Exemptive and Safe Harbor Framework Fifth Circuit Rejects OFAC Sanction of Tornado Cash Crypto Code

Hard Fork Transactions

IRS Clarifies Guidance on Hard Fork Transactions, Offers None on Promotional Airdrops

Initial Exchange Offerings

Gibraltar-Based INX Ltd. Launches SEC-Registered Security Token IPO SEC Issues Investor Alert on Initial Exchange Offerings (IEOs)

IRS

Treasury Department and IRS Propose Digital Asset Broker Regulations Congress Overturns IRS Reporting Rules for DeFi Platforms Delay on Reporting Digital Asset Transactions

New York

NYDFS Updates Guidance on Virtual Coin-Listing/Delisting Frameworks and the Greenlist New York’s Proposed Moratorium on Cryptocurrency Mining Operations NYDFS Becomes First US Financial Regulator to Issue Stablecoin Expectations to Virtual Currency Industry

NFT

SEC Charges Media and Entertainment Co. for Unregistered Offering of NFTs 8 Influencers Charged in $100 Million Securities Fraud Scheme NFT Endorsed by Celebrities Prompts Class Action

Office of the Comptroller of the Currency

Federal Reserve and FDIC Withdraw Crypto-Asset Guidance for Banks; OCC Issues Clarification for Banks Federal Reserve, FDIC, and OCC Issue 2nd Joint Statement Highlighting Liquidity Risks to Banks Engaged in Crypto-Asset-Related Activities Federal Reserve, FDIC, and OCC Issue the First Joint Statement on Crypto-Asset Risks to Banking Organizations

President Trump's Administration

CFTC Opens Door to Spot Crypto Trading on Regulated Exchanges GENIUS Act Enacted, Establishing a Regulatory Framework for Payment Stablecoins Issued or Sold in the United States

PWG

President’s Working Group on Financial Markets Releases Report and Recommendations on Stablecoins

Regulatory & Compliance

SEC Clarifies Status of Crypto Assets Under Federal Securities Laws, Signals Potential Exemptive and Safe Harbor Framework Nasdaq Proposes Rule Changes to Enable Trading of Tokenized Securities SEC Staff Declares Certain Protocol Staking Not a Security Transaction

SEC Enforcement

SEC Clarifies Status of Crypto Assets Under Federal Securities Laws, Signals Potential Exemptive and Safe Harbor Framework SEC Issues Guidance on Applying Federal Securities Laws to Tokenized Securities Nasdaq Proposes Rule Changes to Enable Trading of Tokenized Securities

Securities Law

SEC Staff Clarifies Broker-Dealer Registration Expectations for Non-Custodial Crypto Wallet Providers SEC Clarifies Status of Crypto Assets Under Federal Securities Laws, Signals Potential Exemptive and Safe Harbor Framework SEC Issues Guidance on Applying Federal Securities Laws to Tokenized Securities

Stablecoin

SEC Clarifies Stance on Reserve-Backed Stablecoins Will Cryptocurrency Legislation Gain Momentum in September?Greenberg Traurig contributes UK chapter to Chambers’ Blockchain Guide 2022

State and Local

Hawaii’s Money Transmitters Modernization Act Will No Longer Apply to Cryptocurrency Activities NYDFS Becomes First US Financial Regulator to Issue Stablecoin Expectations to Virtual Currency Industry California State Assembly Introduces Legislation to Establish Digital Financial Assets Law

Tax

Congress Overturns IRS Reporting Rules for DeFi Platforms Delay on Reporting Digital Asset Transactions Treasury and IRS Issue New Proposed Regulations on Digital Assets

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Greenberg Traurig’s global Blockchain & Digital Assets Group comprises more than 100 attorneys across multiple legal disciplines in key financial hubs around the world, providing a centralized approach to blockchain and digital asset matters. We leverage our diverse experience to advise clients on matters ranging from token structuring, fund formation, investment strategies, financial regulation and registration, international tax planning and structuring, stable coins and asset-backed digital assets, infrastructure applications, technology licensing and development, mining, securities compliance, cryptocurrency exchanges and trading, and blockchain-as-a-service.

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SEC Staff Clarifies Broker-Dealer Registration Expectations for Non-Custodial Crypto Wallet Providers
The Rise of Digital Debt Securities in the Middle East
SEC Clarifies Status of Crypto Assets Under Federal Securities Laws, Signals Potential Exemptive and Safe Harbor Framework
Treasury Department and IRS Propose Digital Asset Broker Regulations
SEC Issues Guidance on Applying Federal Securities Laws to Tokenized Securities

Overheard on the Block(chain)

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About Greenberg Traurig

Greenberg Traurig, LLP has more than 3,100 lawyers across 51 locations in the United States, Europe, the Middle East, Latin America, and Asia. The firm’s broad geographic and practice range enables the delivery of innovative and strategic legal services across borders and industries. Recognized as a 2025 BTI “Best of the Best Recommended Law Firm” by general counsel for trust and relationship management, Greenberg Traurig is consistently ranked among the top firms on the Am Law Global 100, NLJ 500, and Law360 400. Greenberg Traurig is also known for its philanthropic giving, culture, innovation, and pro bono work. Web: www.gtlaw.com.

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