A Series Of 1st-Time Crypto Actions For The SEC

December 21

On December 17 we published an article in Law360 describing the SEC’s busy November in which it secured three “firsts” in its crackdown on unlawful digital activity: (1) its first enforcement action against an entity for operating as an unregulated national securities exchange; (2) its first cases imposing civil penalties solely for ICO securities offering registration violations; and (3) its first cases charging touting violations involving ICOs.  By highlighting its own “firsts,” the SEC was sending the message that its actions will match its rhetoric and that it will be using all available avenues to reach those who abuse blockchain and smart contract technology at the expense of the investing public.

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David Zaslowsky has a degree in computer science and, before going to Yale Law School, was a computer programmer. He is currently the Chairman of the Litigation Department of the firm’s New York office. His practice focuses on international litigation and arbitration. He has been involved in cases in trial and appellate courts across the United States and before arbitral institutions around the world. Many of David’s cases, including some patent cases, have related to technology. Since 2008, David has been included in Chambers for his expertise in international arbitration.
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Patrick Dennien is an associate in the Firm’s Washington, DC office. He practices in white collar crime and corporate investigations, sanction systems of international organizations, money laundering risk and AML regulation, cryptocurrency risk and regulation, and corporate compliance programs. Prior to joining the Firm, Patrick worked for the World Bank’s anti-corruption arm, where he assessed the compliance programs of multinational companies, and advised on the development and implementation of effective compliance programs.
Ansley is a derivatives attorney in the Firm’s Global Derivatives and Hedge Fund practice. She regularly advises clients on a broad array of regulatory, transactional and enforcement matters involving the financial markets and financial products. Prior to joining Baker McKenzie, Ansley served in the general counsel department of the National Futures Association, where she advised on regulatory matters related to futures, forex and swaps, including provisional registration reviews of US and non-US swap dealers.

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