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Keith’s experience representing clients in the financial services industry as a litigation, compliance, regulatory, investigations (internal and regulatory), and enforcement attorney spans 20 years. Keith represents clients against government regulators (CFPB, FTC, SEC, CFTC), industry regulators (FINRA), and private litigants in federal courts, state courts, and before arbitration and administrative law panels in the financial services industry.

On May 4, following in the footsteps of President Biden’s recent executive order (Federal EO), California Governor Gavin Newsom issued his own blockchain-related executive order (CA EO), making California the first among the states to endorse a proactive, harmonized approach to regulate blockchain technology. The CA EO assesses how existing state and public institutions may

On April 28, the Joint Chiefs of Global Tax Enforcement (the J5), a global joint operational taxation group consisting of Australia, Canada, Netherlands, United Kingdom, and the United States, issued an intelligence bulletin (Bulletin), enumerating its perceived dangers of non-fungible tokens (NFTs).

NFTs, ERC-20, and Fungibility

Cryptocurrencies and NFTs are similar in the sense that

On May 4, the Connecticut Banking Commissioner issued a temporary order to cease and desist and order to make restitution against lead generator SoLo Funds Inc. (SoLo) for allegedly engaging in unfair, deceptive, and abusive acts and practices (UDAAPs) in violation of the Consumer Financial Protection Act of 2010, as well as for operating in

On May 19, the Department of Commerce’s International Trade Administration issued a Request for Comment (RFC), seeking public input on the development of a framework for driving economic competitiveness and leadership in, and leveraging of, digital asset technologies as part of reinforcing U.S. leadership in the global financial system. This RFC is in response to

On May 2, the Consumer Financial Protection Bureau (CFPB or Bureau) released its Supervisory Highlights report on legal violations discovered during examinations in the second half of 2021.

The Supervisory Highlights detail issues identified by CFPB examination teams across a wide number of segments of the consumer financial services industry. Summarized below are those issues

On March 9, Wyoming amended the Decentralized Autonomous Organizations (DAO) Supplement (Supplement), which permits decentralized autonomous organizations (DAOs) to incorporate and obtain legal status as limited liability companies under Wyoming’s Limited Liability Company Act. The most distinctive modification of the Supplement concerns the minimum threshold of a DAO’s overall membership that must participate in proposal

On March 31, Idaho Governor Brad Little signed HB 583, the Digital Asset Act. The bill amends Title 28 of the Idaho Code, which governs commercial transactions generally, to include a new chapter dedicated to regulation of digital assets. The bill goes into effect on July 1. Idaho’s bill is multifaceted:

(1) It distinguishes

On March 31, the Securities and Exchange Commission (SEC) issued Staff Accounting Bulletin No. 121 (Bulletin), noting that a company safeguarding or exerting custody over cryptocurrency on behalf of its platform users must clearly report the users’ assets as liabilities on the company’s financial statement, along with the risks consumers face by entrusting the company

On April 6, Senator Pat Toomey (R-PA) released a draft of his proposed stablecoin legislation titled, Stablecoin Transparency of Reserves and Uniform Safe Transactions Act, or the Stablecoin TRUST Act. Toomey, the ranking member of the Senate Banking Committee, has been a vocal proponent of blockchain innovation, and his recent bill calls for a deft