On September 11, the Securities and Exchange Commission and Financial Industry Regulatory Authority separately announced three “first of their kind” enforcement actions related to digital assets. Over the past year, regulators have repeatedly stressed the need for compliance with the securities laws when transacting in digital assets that are securities. These actions emphasize the need for all market participants — not just issuers — to comply with the securities laws, and further underscore that compliance with the securities laws extends beyond avoiding fraudulent conduct.
Additional contributors to this post:
Nathan A. Howell, NHOWELL@SIDLEY.COM
Verity A. Van Tassel Richards, VVANTASSELRICHARDS@SIDLEY.COM
Daniel Engoren, DENGOREN@SIDLEY.COM
