Year: 2019

A central question in all of the crypto currency actions brought by the Commission is whether the interests being offered to investors are in fact securities. The seminal decision is, of course, the 1946 decision of the Supreme Court in …

Circuit Court Rejects SEC Claims on Howey Security Test

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During the current partial government shutdown when few SEC Enforcement actions are being filed or settled it may be a good time to begin considering the future of the program. The Division has repeatedly announced that its focus is retail …

The Future Course of SEC Enforcement Read More »

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