Sky Blog
For more than a century, exchanges have governed markets as much as they have operated them. While creating liquidity, they have also functioned as private lawmakers within a public regulatory framework by establishing listing standards and disclosure obligations, monitoring issuers, …
For a decade, a development team that wanted to distribute tokens in the U.S. or to U.S. persons had two realistic options: attempt an SEC registration that, basically, no one could complete, or make a judgment call under the 1946 …
On August 18, 2026, the Securities and Exchange Commission proposed Regulation Crypto Assets, an offering and disclosure framework for “covered investment contracts” involving crypto assets that are not themselves securities. The proposal represents the next phase of the SEC’s “Project …
Today [August 18], the Commission continues its work to restore American leadership in capital formation by developing tailored, fit-for-purpose rules that are designed to support innovation in crypto asset markets.
Given the progress made in Congress to date on market …
The Securities and Exchange Commission (SEC) on March 17 issued an interpretation clarifying how the federal securities laws apply to certain crypto assets and transactions involving crypto assets. This is a major step in the Commission’s efforts to provide greater …
In a new article, we show that jurisdictions treat crypto-derivatives inconsistently, resulting in a regulatory landscape that raises prudential and investor-protection concerns. This divergence is particularly striking given that crypto-derivatives overwhelmingly replicate traditional derivatives in their contractual structure, payoff …
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In an important development for the asset management industry, the Staff of the SEC’s Division of Investment Management issued a no-action letter to Simpson Thacher in response to our request for confirmation that state-chartered trust companies—which are among the most …
Today [September 4], the Office of Information and Regulatory Affairs released the Spring 2025 Unified Agenda of Regulatory and Deregulatory Actions.
This regulatory agenda reflects that it is a new day at the Securities and Exchange Commission. The items …
The SEC’s Division of Trading and Markets and the CFTC’s Division of Market Oversight and Division of Clearing and Risk (collectively, the “Divisions”)[1] are announcing a cross-agency initiative in furtherance of the SEC’s Project Crypto and the CFTC’s Crypto …
On July 1, 2025, the Staff of the Division of Corporation Finance (the “Staff”) of the U.S. Securities and Exchange Commission (SEC) released new guidance[1] on disclosure requirements for offerings and registrations of securities by crypto asset exchange-traded product …
As regulators and policymakers across the federal government press forward with creating long-sought rules of the road for the cryptoasset industry, several recent developments bear particular significance for the promise of the decentralized internet, or Web3. Among these is the …
Congress seems on its way to passing the first piece of federal crypto-regulation, the Guiding and Establishing National Innovation for U.S. Stablecoins – or GENIUS – Act. The law would create a comprehensive regulatory framework for payment stablecoins, which are …
On April 7, 2025, Deputy Attorney General Todd Blanche issued a memorandum to all Department of Justice employees (the “Memorandum”) announcing an overhaul of previous enforcement directives relating to digital assets. The Deputy Attorney General issued the Memorandum consistent with …
The lead of the U.S. Securities and Exchange Commission’s (SEC’s) new Crypto Task Force (Task Force), Commissioner Hester Peirce, recently laid out principles for how the Task Force will approach regulation and provided a roadmap for specific issues the Task …
In its approach to digital assets, the Securities and Exchange Commission has been criticized for regulating by enforcement. In reality, the SEC has taken a twofold approach. In addition to bringing lawsuits against crypto exchanges, the commission has proposed amending …