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Donald Mills

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DJ Mills is an associate within the firm's Financial Services practice group and centers his practice on emerging and established fintech companies, with an emphasis on the digital asset custody space. He assists clients with a broad range of regulatory and transactional matters, including those that implicate money services, securities, and banking law.

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What Happened?

The New York Department of Financial Services (NYDFS or Department) released proposed updates to its guidance on the self-certification process for listing and delisting digital assets. It also announced significant changes to the Department’s “Greenlist” of vetted digital assets.

This industry development affects companies that have received permission to engage in virtual currency…

Weekly Fintech Focus

  • Treasury Releases National Risk Assessments
  • SEC Probing NFT Market
  • Russia/Ukraine Sanctions Overview
  • Summary of Industry Responses
  • BitConnect Founder Flees India After Being Indicted In $2B Ponzi Scheme
  • UK Government to Crackdown on Illegal Cryptocurrency Activity
  • Swiss City of Lugano to Make Bitcoin and Tether ‘De Facto’ Legal Tender

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Continue Reading Blockchain Week in Review: Week of February 28, 2022

Weekly Fintech Focus

  • U.S. Congress to Hold Oversight Hearing on the Mining of Cryptocurrency
  • NY DFS to Hire New Deputy Superintendent
  • Recent Federal Regulator Announcements Signal Changes in Senior Leadership at the SEC, CFTC, and FDIC
  • CFTC Fines Crypto Betting Service Polymarket $1.4M for Unregistered Swaps
  • Australian Open Offers NFT Sales Alongside 2022 Tournament
  • ESMA Releases Request for Evidence Regarding Regulation on Distributed Ledger Technology

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Continue Reading Virtual Currency Legal Report: Week of January 7, 2022

Weekly Focus:

  • BitMEX CEO to Surrender on AML Charges
  • Twitter Scammer Agrees to Three Years’ Jail Time
  • Irish Central Bank Expanding AML Enforcement to Cryptocurrency Companies
  • European Regulators Warn Investors of “High Risk,” Non-Regulated Crypto Assets
  • UK Watchdog ASA Banned Advertisement for Cryptocurrency Company
  • Visa to Allow Merchants to Accept Bitcoin as Payment

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Continue Reading Blockchain Week in Review: Week of March 19, 2021

Weekly Focus:

  • US Senate Confirms Janet Yellen as Secretary of the Treasury
  • FinCEN Extends Comment Period for Rulemaking on Cryptocurrency Transaction Requirements
  • Hawaii’s Digital Currency Innovation Lab Reopens for Applications
  • Philippines Central Bank Issues Anti-Money Laundering Guidelines for Cryptocurrency
  • Bank of International Settlements Publishes Survey on Central Bank Digital Currency
  • Coinbase Announces More Details Related to Its Proposed Public Offering
  • Valkyrie Investments Files Application for Bitcoin ETF

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Continue Reading Blockchain Week in Review: Week of January 29, 2021

Weekly Focus

  • Federal Reserve Publishes Observations From “FooWire” Project
  • Federal Reserve Governor Lael Brainard Announces Collaboration With MIT
  • SEC Appoints New Director of Enforcement
  • Companies Accepted to Hawaii Regulatory Sandbox Begin Providing Services
  • Prosecutors Unseal Charges Against Crypto Mining Ponzi Scheme
  • Monetary Authority of Singapore and Industry Groups Roll Out “Code of Practice” for Payment Service Provider Licensing
  • China Expanding its Digital Currency Testing Program

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Continue Reading Blockchain Week in Review: Week of August 21, 2020

Weekly Focus:

  • ICO Issuer Settles SEC Registration Charges
  • IRS and Cryptocurrency Industry Groups to Meet Amid Agency Enforcement Push
  • Washington Blockchain Work Group Bill Passes State Senate
  • Brazilian Central Bank to Launch Payment System to Compete With Cryptocurrencies
  • Financial Intelligence Units Meet to Discuss Global Issues Surrounding Virtual Assets
  • Bank of Korea to Leverage Blockchain Technology in Bond Market
  • DeFi Project, bZx, Loses $630,000 in Ether in Second “Flash Loan” Exploit in a Week
  • Coinbase Given Principal Status With Visa

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Continue Reading Blockchain Week in Review: Week of February 21, 2020

U.S. Developments

Telegram Submits Answer to SEC Complaint Regarding TON Blockchain Network

On November 12, Telegram Group Inc. (Telegram) submitted its answer and affirmative defenses to a complaint filed against it by the U.S. Securities and Exchange Commission (SEC) in federal court. The SEC previously filed an emergency action against Telegram and received a temporary restraining order to prohibit the launch of the Telegram Open Network (TON) blockchain and the issuance of “Grams,” the company’s virtual currency.

In its answer to the SEC complaint, Telegram argues that its offering of investment contracts known as “Simple Agreements for Future Tokens” or “SAFTs” were compliant with the federal securities laws and offered pursuant to a valid exemption from the registration requirements under the Securities Act of 1933. The company also maintains that its actions regarding the SAFTs were consistent with the guidance offered by the SEC at the time and were conducted in good faith based upon the public comments made by SEC officials at the time. Specifically, Telegram cites various SEC statements and actions on the subject.
Continue Reading Blockchain Week in Review: Week of November 15, 2019

Arizona’s financial technology (“fintech”) sandbox (“Sandbox”), the first of its kind in the United States, has been open for several months and has accepted three participants.  A month after the program’s launch, Arizona’s Attorney General announced his approval of the first participant, payment platform Omni Mobile, Inc.[1]  Two other companies providing consumer lending services, Sweetbridge NFP, Ltd. and Grain Technology, Inc., joined Omni as Sandbox participants shortly thereafter.[2]  Arizona’s Sandbox may serve as a helpful illustration of what entrepreneurs can expect in Arizona (should they also wish to participate in the Sandbox) as well as in other states that decide to implement similar programs.[3]  To that end, this client update provides an overview of regulatory sandboxes generally, Arizona’s Sandbox, and potential future developments.
Continue Reading Fintech Regulatory Sandboxes: Update on Arizona’s Sandbox and Other Developments