The first of what may be a series of crypto no-action letters supports the view that programmatic token distributions serving as network incentives are not securities.
By Jenny Cieplak, Paul M. Dudek, Zachary Fallon, Stephen P. Wink, Hank Balaban, Daphne Lambadariou, and Deric Behar
On September 29, 2025, the SEC Division of Corporation Finance issued a no-action letter (NAL) stating that it would not recommend enforcement against a certain foundation company and blockchain token
The agencies pledge to “usher in a new era of innovation” through a collaboration on rules and exemptions that aims to provide digital asset markets with clarity.
By Stephen P. Wink, Zachary Fallon, Yvette D. Valdez, Douglas K. Yatter, Jenny Cieplak, Adam Bruce Fovent, and Deric Behar
The SEC’s Project Crypto and the CFTC’s Crypto Sprint were launched over the summer to implement the recommendations of the President’s Working Group on Digital Asset Markets
The Staff provides the market with additional crypto clarity, holding that liquid staking does not qualify as a security under the Howey test.
By Jenny Cieplak, Zachary Fallon, Yvette D. Valdez, Stephen P. Wink, Hank Balaban,* Adam Bruce Fovent, Daphne Lambadariou, and Deric Behar
On August 5, 2025, the SEC’s Division of Corporation Finance (the Staff or Division) published a Statement on Certain Liquid Staking Activities clarifying that, in the Staff’s view, liquid