On March 10, the New York State Department of Financial Services (DFS) issued guidance and a request for assurance to financial institutions engaged in virtual currency business activity in New York. The request requires regulated virtual currency businesses to prepare and submit a plan of preparedness to manage the risk of disruption to services and operations caused by the novel coronavirus known as “COVID-19”.
Continue Reading Client Alert: COVID-19 Preparedness Plan Requirements For NY Virtual Currency Businesses

The SEC and FINRA recently announced a series of enforcement actions against new types of actors in the digital asset space—private fund managers and broker-dealers.
Continue Reading SEC and FINRA Target Cryptocurrency Hedge Fund Manager and Broker-Dealers in New Wave of Digital Asset Enforcement Proceedings

Why Blockchain Custody Is So Difficult—A Hard Part” was recently posted on Perkins Coie’s Asset Management ADVocate blog. The blog post continues the analysis of the difficult question of how to comply with regulations requiring independent custody of cryptocurrency. This series focuses on the custody requirements for registered investment companies in an attempt

Why Blockchain Custody Is So Difficult—The Simple Part” was recently posted on Perkins Coie’s Asset Management ADVocate blog. The post begins with an analysis of the difficult question of how to comply with regulations requiring independent custody of cryptocurrency. This series will focus on the custody requirements for registered investment companies in an