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's ("SEC") Office of Compliance Inspections and Examinations ("OCIE") published the 2019 Examination Priorities on December 20, 2018.