We have been active in the digital asset space since 2014, initially setting up Bitcoin funds and robo advisors. We also assist our FINRA Broker-Dealer clients with compliance issues relating to crypto assets including AML/KYC requirements, FinCen requirements, and New York BitLicense filings.
SEC and CFTC Compliance Services
We also assist our clients with SEC and CFTC exams and subpoena responses and advise on IRS rules and corporate structures for ICOs and crypto funds. We also evaluate custody issues for
Crypto custodian clients (and fund clients) and valuation issues for crypto administrator clients. Moreover, we assist with non-US regulations relating to the global distributions of ICOs and STOs. Finally, we provide AML and Escrow Services for private bulk sales of virtual currencies.
ATS Application Services
We also assist clients with ATS applications (to facilitate the trading of digital assets and virtual currencies) and with Form D/blue sky filings for our Reg D and Reg S clients.
The U.S. Securities and Exchange Commission ("SEC" or "Commission") the Financial Industry Regulatory Authority ("FINRA") released a joint statement on July 8, 2019 clarifying issues related to broker-dealer custody of digital asset securities. The statement focuses on FINRA and the SEC's approach to broker-dealer regulation and investor protection, including assets deemed to be securities under the 1970 Securities Investor Protection Act and factors related to approving a broker-dealer application of crypto-related companies. The same fundamental elements of the broker-dealer financial responsibility rules apply whether a security is paper or digital.
The U.S. Securities and Exchange Commission's ("SEC") Office of Compliance Inspections and Examinations ("OCIE") published the 2019 Examination Priorities on December 20, 2018.
For the past few years, we’ve brought great speakers, original topics and new faces to our alternative investment sessions. This year promises to be the best ever. Join us at the 12th Annual Alternative Investment Management Seminar on Thursday, November 14, 2019.