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OCIE Issues Risk Alert on Cash Solicitation Rule

The Securities and Exchange Commission’s Office of Compliance Inspections and Examinations (the “OCIE”) has issued, on October 31, 2018, a Risk Alert concerning compliance with the so-called Cash Solicitation Rule (Rule 206(4)-3 under the Investment Advisers Act of 1940 (the “Advisers Act”)).  The rule requires investment advisers required to be registered under the Advisers Act... Read more »

SEC Cease and Desist Against Alleged Unlicensed Cryptocurrency Exchange

On November 8, 2018, the Securities and Exchange Commission (the “SEC”) published a press release announcing that it had settled its first cease and desist enforcement action concerning a cryptocurrency trading platform, against Zachary Coburn, the founder of EtherDelta.  The SEC has alleged that EtherDelta was an unregistered national securities exchange in that it provided a... Read more »

SEC Acts Against Cryptocurrency Companies

On October 11, 2018, Securities and Exchange Commission (the “SEC”), the SEC issued a press release announcing that it had obtained an emergency court order to stop an Initial Coin Offering (an “ICO”) by Blockvest LLC and its founder, Reginald Buddy Ringgold, III. Among other things, the company claimed that the ICO had been approved by the... Read more »

CFIUS Guidelines for Mandatory Critical Technology Reporting

We previously reported on the updates made to the implementing legislation of the Committee on Foreign Investment in the United States (“CFIUS”) by the Foreign Investment Risk Review Modernization Act of 2018 (“FIRRMA”).  Among other things, FIRRMA mandated reporting of transactions that involve acquisition of critical technologies in the United States.  On October 11, 2018,... Read more »

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