This article covers the regulatory trends and hot topics in the Web3 virtual asset jurisdictions of Hong Kong, the EU, the UK, the UAE, Japan, Korea, and the US in the first half of 2023. After the confusion and pains of the early stage, global regulatory agencies tend to cooperate and gradually establish a standardized regulatory framework for Web3 virtual assets to implement KYC/AML/CTF at the FATF level, while focusing on protecting investors and regulating benign market development.
In contrast, the SEC in the United States directly targeted the regulatory bottom line in the lawsuit against Coinbase, namely, “What kind of virtual asset is a security?” Once this issue is clarified, all current regulatory uncertainties and opaqueness will be resolved, including the registration of Security Tokens, exchanges, custody, brokerage, clearing business registration, and possibly direct regulation coverage of DEX and DeFi. The continuous regulation of the market also further promotes the entry of Wall Street capital. After the regulatory clarification, the United States or the world may form a unified Web3 virtual asset market. Of course, the inevitable tearing and pains from the U.S. executive, judicial, and legislative levels are currently present, and the answer may be revealed in the election year of 2024. Let us wait and see.
1. Hong Kong introduces a brand new Virtual Asset Service Provider (VASP) system
With the issuance of the “Policy Statement on Virtual Assets Development in Hong Kong” in October last year, the brand new Virtual Asset VASP system [1] was officially launched in China’s Hong Kong virtual asset industry on June 1, 2023, which is a significant positive development.
As early as 2018, the Hong Kong Securities and Futures Commission gradually established a “voluntary issuance” system for security-type token virtual assets, clearly stating that the Hong Kong Securities and Futures Commission has no regulatory power over virtual asset trading platforms that only buy and sell non-security-type tokens. Under the “voluntary issuance” system, if it is a virtual asset trading platform that trades non-security-type tokens, it does not need to be licensed.
Today, the virtual asset industry has undergone tremendous changes, and the original “voluntary issuance” system can no longer cover the market that mainly targets retail investors and non-security-type tokens. In order to comprehensively regulate all centralized virtual asset trading platforms in Hong Kong and implement the latest standards of the Financial Action Task Force (FATF), the Hong Kong government has revised the “Anti-Money Laundering Ordinance” and established a brand new VASP “mandatory issuance” system to achieve a more appropriate balance between investor protection and market development.
MiCA is part of the EU’s Digital Finance Strategy and will standardize the following rules for EU member states: transparency and disclosure requirements for access to the issuance and trading of crypto assets; authorization and regulation of crypto asset service providers and issuers; operating, organizational, and governance rules for asset-referenced tokens, electronic money tokens, and other crypto asset service providers; consumer protection rules for crypto assets; and measures to prevent market abuse and ensure the integrity of the crypto asset market.
MiCA fills a gap in the current EU financial regulatory framework by establishing a virtual asset regulatory framework that applies to all entities participating in the issuance of virtual assets and providing related services in the EU. In general, MiCA mainly regulates: (i) various types of crypto assets, including e-money tokens, asset-referenced tokens, and other tokens; and (2) various types of crypto asset services and service providers, including wallet custody services, deposit and withdrawal services, exchange services, asset management services, and investment advisory services, etc.
(from EU Markets in Crypto-Assets (MiCA) Regulation Expected to Enter into Force in Early 2023, Mayer Brown)
(from: https://paddihansen.substack.com/p/the-eus-mica-framework)
3. UK House of Lords Passes Virtual Currency and Stablecoin Regulation Bill
Following the EU’s introduction of the crypto asset market regulation (MiCA), virtual asset regulation legislation in the UK is catching up. According to reports, the UK House of Lords voted on June 19 to pass the Financial Services and Markets Bill (FSMB) [3], which means that the bill will enter the final stage of signing into law, and the UK is likely to formally regulate virtual asset financial services and markets in the near future.
The bill treats virtual assets as a regulated activity, and first regulates some stablecoins as a payment method. The bill proposes to expand the scope of Part 5 of the Banking Act 2009 to include payment systems using digital settlement assets. This will put some stablecoin activities under the scope of the Financial Conduct Authority (FCA).
Furthermore, the bill will also give new powers to government regulatory bodies, clarifying that these bodies can create new regulated virtual assets and activities to be included in the current framework of traditional financial regulation. Currently, FCA only has the power to ensure that virtual asset companies register and comply with their anti-money laundering rules. The bill also attempts to strengthen coordination between regulatory agencies in decentralized technologies such as new technology, data usage, virtual currencies, stablecoins, NFTs, tokenization, and blockchain.
Web3 Xiao Lu Comments:
As the UK accelerates the clarification of its legal framework for virtual asset regulation, we have observed that institutions facing huge regulatory uncertainty in the United States are also beginning to lay out their plans in the UK. For example, a16z recently announced the establishment of the world’s first international office in London. Coinbase, the largest virtual asset exchange in the United States, which was sued by the SEC this month, also plans to launch a compliant business path in the UK. After Brexit and the loss of many EU financial businesses, the UK government is urgently eager to rebuild London as a financial technology center. We are waiting to see how UK Prime Minister Sunak’s support for the virtual asset industry can break through the conservative political environment in the UK.
4. UAE Issues 2023 Virtual Assets and Regulatory Activities Regulations (VARA Regulation)
On February 7, 2023, the Dubai Virtual Asset Regulatory Authority (VARA) issued the Virtual Assets and Related Activities Regulations 2023[4]. The regulations take effect immediately upon publication and require all market participants conducting virtual asset businesses or providing services in the UAE (except for two financial free zones, ADGM and DIFC) to obtain approval and licensing from the Emirates Securities and Commodities Authority (SCA) or VARA.
The VARA regulations were issued based on the Dubai Virtual Asset Regulatory Law No. (4) of 2022, which previously established the Dubai Virtual Asset Regulatory Authority (VARA) as the world’s first independent government virtual asset regulatory agency. This will create a robust regulatory framework for the governance of virtual assets and blockchain technology in Dubai.
Through the bill, the Financial Supervisory Commission (FSC) of South Korea has the authority to supervise and review virtual asset operators, and the South Korean National Assembly can also establish a virtual asset committee to provide advice on virtual assets. In addition, the second stage of legislation to promote the issuance and disclosure of market information for virtual assets will be formulated later, and Baek Hye-ryun, chairman of the National Assembly’s Political Affairs Committee, said, “Virtual assets have finally entered the scope of the law.”
6. Japan’s largest bank is negotiating the issuance of a global stablecoin
It is reported that Mitsubishi UFJ Financial Group, Japan’s largest bank, is negotiating with global stablecoin issuers and other companies to issue its stablecoin. Tatsuya Saito, Vice President of Mitsubishi UFJ, said that the bank is discussing with multiple parties the use of its blockchain platform Progmat to issue stablecoins pegged to foreign currencies, including the US dollar, for global use. He said that since Japan’s legislation has taken effect, both issuers and users of stablecoins will feel secure. However, he refused to disclose which stablecoin issuers are being negotiated with.
Japan passed the world’s first stablecoin bill, the Funds Settlement Act Amendment, in June 2022, which categorizes stablecoins as virtual currencies and allows licensed banks, registered transfer agents, and trust companies to issue stablecoins. In December 2022, Japan’s financial regulator removed restrictions on overseas stablecoins trading in Japan. Stablecoins, which are in a way between fiat and virtual currencies, are considered a key element in the development of Web3. Stablecoins can be pegged to the yen, and Japanese people can use stablecoins to buy various tokens.
7. Crypto-friendly banks Slivergate Bank and Signature Bank are taken over by the FDIC one by one
On March 1, 2023, Silvergate Bank announced that it was unable to submit its annual 10-K report to the SEC on time and said it may face a “capital shortfall.” Silvergate Bank is a community retail bank in California that positions itself as a gateway to the virtual asset industry, accepting deposits from virtual asset exchanges and institutions, and establishing its own virtual currency settlement and payment network, the Silvergate Exchange Network (SEN) real-time payment system. The system enables virtual asset exchanges, institutions and customers to exchange virtual currencies for fiat currencies.
On November 2022, FTX collapsed, leading to a risk exposure of over $1 billion for Silvergate Bank. More importantly, the collapse of FTX resulted in a severe “bank run”, with Silvergate Bank processing over $8.1 billion in withdrawals. In order to meet the large amount of withdrawals, Silvergate Bank was forced to bear huge losses and urgently sold about $5.2 billion in assets, and obtained a $4.3 billion loan from the Federal Home Loan Bank. On March 8, 2023, Silvergate Bank stated in a filing with the SEC that it would voluntarily liquidate Silvergate Bank according to applicable regulatory procedures. “The bank’s liquidation plan includes full repayment of all deposits and consideration of how best to resolve claims and retain the residual value of its assets, including its proprietary technology and tax assets.” Subsequently, Silvergate Bank was taken over by the Federal Deposit Insurance Corporation (FDIC).
On March 10, 2023, against the background of the Fed’s interest rate hike, a brief 48-hour bank run caused severe liquidity problems for Silicon Valley Bank (SVB) (the 16th largest bank in the United States with a 40-year history), which was taken over by the FDIC. This is the second largest bank failure in US history since the collapse of Washington Mutual in 2008. On March 12, 2023, the Treasury Department, the Fed, and the FDIC issued a joint statement, stating that after consultation, they agreed to complete their rescue of Silicon Valley Bank through the FDIC in a way that fully protects all depositors. From Monday, March 13, depositors will be able to use and withdraw all their money, and losses related to the resolution of Silicon Valley Bank will not be borne by taxpayers.
Due to the impact of Silicon Valley Bank, on March 12, 2023, the US Treasury Department, the Federal Reserve, and the FDIC issued a joint statement announcing the closure of Signature Bank, a crypto-friendly bank, on the grounds of “systemic risk” to prevent the continued spread of the banking crisis. At the same time, NYDFS appointed the FDIC as the receiver to dispose of Signature Bank’s assets, even though Signature Bank had already recovered from the impact of Silicon Valley Bank and had a strong balance sheet at the time.
Web3 Xiao Lu Comments:
US bank regulatory agencies (the OCC at the federal level and state financial regulatory agencies such as the NYDFS at the state level) have the authority to revoke the operating licenses of their subordinate banks due to poor business operations or insolvency. When a bank ceases operations, the Federal Deposit Insurance Corporation (FDIC) is appointed as the manager or receiver of the problem bank (playing an indispensable role in the bank’s relief or liquidation process), protecting depositors’ deposits and minimizing the negative impact of bank closures on the overall financial system. The closure of Silvergate Bank and Signature Bank, two crypto-friendly banks, has brought the virtual asset industry back to the days when virtual assets did not have formal bank accounts many years ago, as any newly established company has no chance of immediately obtaining a banking license.
(from Crypto's Last Stand in the US: USDC, Silvergate, Silicon Valley and Signature Banks Collapse in One Week)
8. US regulatory enforcement against Binance and its founder CZ
8.1 NYDFS requires Blockingxos to stop creating its stablecoin BUSD
On February 13, 2023, Binance CZ issued a statement: The New York State Department of Financial Services (NYDFS) has instructed stablecoin issuer Blockingxos to stop minting new BUSD (BUSD is a stablecoin owned and managed by Blockingxos). At the same time, Blockingxos confirmed that it has received a notice from the SEC regarding potential charges related to its BUSD product.
Blockingxos is a stablecoin issuer registered in New York State, holds a New York State Bitlicense virtual asset operating license, is directly regulated by the NYDFS, its BUSD product is built on the Ethereum blockchain, and is fully reserved in accordance with the 1:1 US dollar assets required by the NYDFS’s stablecoin issuance guidelines released in June 2022. The NYDFS has the right to require Blockingxos to stop issuing BUSD or directly revoke Blockingxos’s Bitlicense license based on the commitment to incomplete user periodic risk assessments and due diligence to prevent compliance issues such as money laundering. NYDFS said that this regulatory measure was taken to clarify the complex issues between Blockingxos and Binance that have not yet been resolved.
Blockingxos replied to NYDFS’s regulatory measures through its official website, stating that as of February 21, Blockingxos will stop issuing new BUSD tokens in accordance with NYDFS’s instructions and will terminate its cooperation with Binance regarding BUSD. In the future, it will launch Blockingx Dollar (USDP) to replace the previous BUSD [9]. Subsequently, NYDFS explained more issues in a report with Bloomberg [10]. The reason for stopping the issuance of BUSD seems to have nothing to do with the security identification of stablecoins. The real reason may be related to Circle’s complaint that Binance-Peg BUSD has poor reserve management.
8.2 CFTC accuses Binance and its founder CZ of intentionally evading US laws and illegally operating a virtual asset derivatives exchange
On March 27, 2023, the US Commodity Futures Trading Commission (CFTC) announced that it had filed a civil lawsuit in a US court, accusing CZ and three entities of operating Binance platform of violating the Commodity Exchange Act (CEA) and CFTC regulations multiple times [11]. According to the indictment, from July 2019 to the present, Binance has provided and executed virtual asset derivative transactions to Americans (although it blocks US IP addresses). Under CZ’s guidance, Binance instructed its employees and customers to deliberately evade US laws by circumventing compliance controls (including VPNs, setting up shell companies, etc.), conducting business in an opaque manner, ignoring CEA and CFTC regulations, and planning regulatory arbitrage to seek commercial benefits [12].
CFTC accused entities like Binance that provide virtual asset derivative services in the US to register as a Futures Commission Merchant (FCM) with CFTC in order to assume compliance obligations similar to KYC and to carry out basic compliance requirements aimed at preventing and investigating terrorist financing and money laundering activities. For Binance’s derivative trading business, it should also register with CFTC as a Designated Contract Market (DCM) or Swap Execution Facility (SEF). However, Binance has never registered with CFTC for anything.
Therefore, CFTC accuses CZ and its affiliates of violating relevant laws and regulations related to futures trading, illegal off-exchange commodity options, failure to register as a futures commission merchant, or designated contract market, or swap execution facility, and failure to supervise, failure to implement KYC or anti-money laundering processes, and failure to develop Qualified compliance plan, etc., seeking civil penalties and permanent trading and registration bans on CZ and its affiliates.
CFTC Chairman Rostin Behnam said, “Today’s enforcement action demonstrates that no region, or region claiming no jurisdiction, can prevent the CFTC from protecting American investors. I have made it clear that the CFTC will continue to use all its powers to discover and stop improper behavior in the tumultuous and high-risk virtual asset industry… For years, Binance has known that they violated CFTC regulations, but actively worked to keep funds flowing and avoid compliance. This should be a warning to everyone in the virtual asset world that the CFTC will not tolerate behavior that deliberately circumvents US law.”
(from CFTC v. Zhao et al, legal opinion given by Samuel Lim, former Binance chief compliance officer)
8.3 SEC Files 13 Charges Against Binance, Among Other Entities and Founder CZ
On June 5, 2023, the SEC filed 13 charges against Binance, among other entities and its founder CZ, including operating unregistered exchanges, broker-dealers, and clearing agencies; conducting false trades and ineffective regulation of Binance US; and issuing and selling unregistered securities.
This enforcement action came after the CFTC Commodity Futures Trading Commission filed a similar lawsuit against Binance in March. In a 136-page complaint [14], the SEC accused CZ and several Binance entities from multiple dimensions: Binance illegally solicited US investors to purchase, sell and trade virtual currencies, and did not restrict US investors’ access to Binance.com; Binance issued and sold securities without registration, including BNB, BUSD, as well as loan products called “Simple Earn” and “BNB Vault”, and the so-called staking investment plan offered on Binance. The SEC also pointed out that Binance secretly controlled the assets pledged by US customers in the BAM staking plan; Binance and several other entities have repeatedly misled investors, allowing them to mix or transfer customer assets at will, including transferring them to Merit Peak Limited, an entity actually controlled by CZ. This corresponds to similar allegations against FTX and its founder Sam; Binance and several other entities should have registered as securities exchanges, broker-dealers, and clearing agencies, but did not; Binance.US lied about preventing market manipulation and allowed an undisclosed “market maker” trading company, Sigma Chain, to conduct washing trades, which is also owned by CZ.
Therefore, whether a single project token is deemed a “security” or not (such as in SEC v. Ripple) is not important. What is important is that when a project is subject to SEC regulatory enforcement, in addition to paying money, the SEC will also require the project to implement an internal control program. As more and more projects adopt this internal control program, it naturally becomes a regulation. This is how Gary Gensler “squeezed out” regulations at the CFTC, which is consistent with the current situation at the SEC.
10. US regulatory agencies actively exploring regulatory paths for DeFi
On April 6, 2023, the US Treasury Department released the 2023 DeFi Illegal Financial Activities Assessment Report [17], the world’s first assessment report on illegal financial activities based on DeFi, and a response to the virtual asset regulatory framework released by the White House in March 2022. Both the Financial Crimes Enforcement Network (FinCEN) under the US Treasury Department and the Office of Foreign Assets Control (OFAC) are important regulatory agencies in the US virtual asset industry and have extraterritorial enforcement powers. FinCEN is responsible for preventing and punishing domestic and international money laundering activities, combating terrorist financing and other financial crimes, and collecting and analyzing financial transaction information. By studying the mandatory disclosure information of financial institutions, tracking suspicious individuals and activities, OFAC is responsible for managing and enforcing all economic and trade sanctions based on US national security and foreign policy.
First, the report outlines the market structure of the DeFi ecosystem, and DeFi services are widely defined as DeFi platforms, exchanges, applications, organizations, and other forms of decentralized exchanges (DEXs), decentralized lending platforms, pledging pools (Yield Protocols), cross-chain bridges, liquidity staking, decentralized algorithmic stablecoins, etc., but do not include DeFi services that are conducted through self-custody wallets. Then, the report points out that in reality, most so-called DeFi is still centralized, usually controlled by an organization and providing a certain degree of centralized management and governance. The report demonstrates how illegal actors abuse DeFi services to engage in illegal activities and profit from them, especially in ransomware attacks, theft, fraud, drug trafficking, and proliferation financing. In addition, the report identifies vulnerabilities where criminals can use DeFi services to engage in illegal financial activities, including non-compliance with anti-money laundering/combating the financing of terrorism (AML/CFT) and sanctions obligations, risks of decentralization, and regulatory vacuums in overseas jurisdictions where international AML/CFT standards are not being met. Finally, the report recommends that the United States strengthen its AML/CFT regulations and, where possible, strengthen enforcement of virtual asset activities (including DeFi services) to enhance compliance with BSA obligations by virtual asset service providers.
Web3 Xiao Lu Comments:
After the US regulatory agency OFAC sanctioned the Tornado Cash DeFi protocol from an AML/CTF perspective in August 2022, the US regulatory agency CFTC expanded the regulatory dimension of on-chain DeFi projects in the victorious case of Ooki DAO [18]. CFTC directly defined the on-chain DAO as an illegal organization for the reason of Ooki DAO’s illegal business violations, opening up the precedent that on-chain DAOs can be the subject of legal action and bear legal responsibility. More frighteningly, all participating governance members may bear joint liability for DAOs. After DAOs can be sued, the on-chain is no longer a lawless place, and regulatory enforcement agencies can use this as a breakthrough to regulate on-chain DAOs, DeFi, and DEX projects.
The challenges posed by DeFi’s financial stability (DeFi and the virtual asset ecology, DeFi and traditional finance), the anonymity of DeFi data leading to opacity, the lack of market integrity in the DeFi and virtual asset industry, and DeFi network hacker network security all challenge the current regulatory framework. Issues such as how to determine the responsible subject of DeFi projects, how to solve the centralization of DeFi projects, and how to solve regulatory arbitrage in DeFi projects are all issues that urgently need to be addressed by regulators.
11. SEC’s regulatory guidance on virtual asset custody attracts Wall Street capital
On February 15, 2023, the SEC released a proposed rule on qualified custodians for investment advisers, further raising the custody requirements for virtual assets and expanding the requirements to include investment advisers such as funds, requiring them to hold relevant virtual assets using qualified custodians [19].
SEC Chairman Gary Gensler emphasized that the current regulations, which date back to 2009, cover a large number of virtual assets and subject them to regulation. Although some virtual asset trading and lending platforms claim to be able to custody investors’ virtual assets, this does not mean that they are qualified custodians. Some platforms have not properly segregated investors’ virtual assets, but instead commingled investors’ assets, resulting in investors’ assets becoming the assets of failed companies in the event of “bank runs” and other similar situations, seriously infringing on investors’ interests. Through this expanded rule on qualified custodians for investment advisers, both investors and investment advisers will receive the protection they deserve.
Gary Gensler talked about the SEC’s regulatory approach to the virtual asset market in his August 2022 work video “What Are Crypto Trading Platforms?”[20]: (1) Based on the well-functioning US Securities Act, protect the interests of investors; (2) It is necessary to split virtual asset exchanges (such as separating brokerage, clearing, and custody businesses) to avoid conflicts of interest and self-dealing.
Web3 Xiao Lu Comments:
SEC’s custody regulations will encourage investors to entrust their virtual assets to licensed institutions or mainstream banks. At the same time, this will enable banking and financial regulators to review virtual asset activities. In practice, we see that entities with custody businesses have obtained relevant trust charters at the state level and are subject to state financial regulatory supervision. Anchorage Digital Bank has gone further and obtained approval from the Office of the Comptroller of the Currency, the federal agency that oversees US banking institutions, to become a truly federally chartered virtual asset bank.
One of the biggest concerns of traditional finance entering the virtual asset market is the security of asset custody. Traditional finance cannot hand over assets to centralized exchanges like FTX for fund security considerations. Professional virtual asset custody institutions that are regulated, such as Anchorage Digital Bank, can solve asset security issues and provide solutions for asset audits, insurance, etc., making them one of the safe choices for traditional financial institutions.
(https://edxmarkets.com/)
We see that EDX Markets, a new virtual asset trading platform supported by Wall Street forces such as Citadel Securities, Fidelity Investments, and Charles Schwab, will be launched soon. It has also received financing from Sequoia Capital, Blockingradigm, and Virtu Financial. It is dedicated to serving institutional investors and will provide spot trading of four virtual currencies, BTC, ETH, LTC, and BCH, none of which are classified as securities by the SEC.
EDX Markets CEO Jamil Nazarali stated that it will cooperate with third-party custodians and plans to launch the clearing institution EDX Clearing later this year to settle transactions on the EDX Markets platform. So far, the future development path of EDX Markets seems to have become clear: to provide a market with higher transparency, only non-custodial trading matching is done to meet regulatory compliance requirements, and serve institutional investors.
Previously, SEC Chairman Gary Gensler pointed out that virtual asset exchanges mix multiple functions. In the traditional financial field, the New York Stock Exchange will not act as a market maker like a hedge fund. Implicitly, he believes that the current exchanges are too large, combining trading, market making, and custody. This is reflected in events such as FTX, Celsius, and DCG/Genesis. Therefore, the SEC’s subsequent virtual asset custody new regulations (proposal) can refer to the 1933 Glass Steagall Act (strictly separating the investment banking business and commercial banking business of banks to avoid risks brought by investment banking business) against the background of the Great Depression, as well as the 2010 Dodd Frank Act (splitting the speculative proprietary trading of large financial institutions, strengthening supervision of financial derivatives to prevent systemic financial risks) against the background of the subprime crisis. These are bloody lessons.
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This article is for learning and reference only, and I hope it can be helpful to you. It does not constitute any legal or investment advice, not your lawyer, DYOR.
REFERENCE:
[1] Consultation Conclusions on the Proposed Regulatory Requirements for Virtual Asset Trading Platform Operators Licensed by the Securities and Futures Commission
https://apps.sfc.hk/edistributionWeb/api/consultation/conclusion?lang=EN&refNo=23CP1
[2] REGULATION OF THE EUROPEAN BlockingRLIAMENT AND OF THE COUNCIL on Markets in Crypto-assets, and amending Directive (EU) 2019/1937
https://eur-lex.euroBlocking.eu/legal-content/EN/TXT/?uri=CELEX%3A52020PC0593
[3] UK Blockingrliament,Financial Services and Markets Bill
https://bills.parliament.uk/bills/3326
[4] VARA, Virtual Assets and Related Activities Regulations 2023
https://www.vara.ae/en/regulations/regulations-and-guidelines/
[5] UAE central bank issues AML/CTF guidance for dealing with virtual assets
https://www.reuters.com/technology/uae-central-bank-issues-amlctf-guidance-dealing-with-virtual-assets-2023-05-31/
[6] Crypto Exchange OKX Wins PreBlockingratory License in Dubai, Set to Boost Staff
https://www.coindesk.com/business/2023/06/15/crypto-exchange-okx-wins-preBlockingratory-license-in-dubai-set-to-boost-staff/
[7] Protection of virtual asset investors in Korea and obligations imposed on virtual asset service providers
https://www.lexology.com/library/detail.aspx?g=2c2f8d35-9dac-4921-ad10-500eb2f40572
[8] Signature Bank, Joint Statement by the DeBlockingrtment of the Treasury, Federal Reserve, and FDIC
https://www.fdic.gov/news/press-releases/2023/pr23017.html
[9] Blockingxos Issues Statement
https://paxos.com/2023/02/13/paxos-issues-statement/
[10] Bloomberg, Stablecoin Issuer Circle Warned Watchdog About Binance Token
https://news.bloomberglaw.com/securities-law/stablecoin-issuer-circle-warned-ny-watchdog-about-binance-token
[11] CFTC Charges Binance and Its Founder, Changpeng Zhao, with Willful Evasion of Federal Law and Operating an Illegal Digital Asset Derivatives Exchange
https://www.cftc.gov/PressRoom/PressReleases/8680-23
[12]Commodity Futures Trading Commission v. Zhao et al
https://www.courtlistener.com/docket/67092867/1/commodity-futures-trading-commission-v-zhao/
[13] SEC Files 13 Charges Against Binance Entities and Founder Changpeng Zhao
https://www.sec.gov/news/press-release/2023-101
[14] SECURITIES AND EXCHANGE COMMISSION v. BINANCE HOLDINGS LIMITED, 1:23-cv-01599, (D.D.C.)
[15] SEC Charges Coinbase for Operating as an Unregistered Securities Exchange, Broker, and Clearing Agency
https://www.sec.gov/news/press-release/2023-102
[16] Securities and Exchange Commission v. Coinbase, Inc., 1:23-cv-04738, (S.D.N.Y.)
https://www.sec.gov/litigation/complaints/2023/comp-pr2023-102.pdf
[17] Treasury Releases 2023 DeFi Illicit Finance Risk Assessment
https://home.treasury.gov/news/press-releases/jy1391
[18] Statement of CFTC Division of Enforcement Director Ian McGinley on the Ooki DAO Litigation Victoryhttps://www.cftc.gov/PressRoom/PressReleases/8715-23
[19] SEC Proposes Enhanced Safeguarding Rule for Registered Investment Advisers
https://www.sec.gov/news/press-release/2023-30
[20]Office Hours with Gary Gensler: What Are Crypto Trading Platforms?
https://www.sec.gov/news/sec-videos/office-hours-gary-gensler-what-are-crypto-trading-platforms
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