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Philip advises companies and individuals on SEC administration matters, including bent administration investigations, centralized investigations, and cryptocurrencies and blockchain technology.



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Philip has all-encompassing acquaintance with balance administration matters. For added than a decade above-mentioned to entering clandestine practice, he served as chief admonition in the SEC’s Division of Enforcement, investigating and prosecuting circuitous affairs involving violations of the federal balance law.

Before actuality active with Seward & Kissel LLP you were a affiliate of the SEC’s Cyber Unit which focused on cryptocurrencies and ICOs. How were you initially recruited for this Cyber Unit?



I started in the SEC’s Administration Division in 2008 and began alive on Bitcoin and cryptocurrency-related affairs about bristles years above-mentioned to the conception of the SEC Cyber Unit. I brought the SEC’s aboriginal Bitcoin-related administration activity adjoin the abettor of Bitcoin Savings & Trust and led added cryptocurrency-related affairs as well. I abreast Chair Mary Jo White and the added Commissioners, and frequently conducted training for the FBI, FINRA, and others, on Bitcoin and blockchain technology. I additionally presented in bookish settings on my work.  So, back the Cyber Unit was formed in 2017, with a authorization that included cryptocurrencies and ICOs, I was a accustomed fit.

 



How did the activity adjoin ‘Bitcoin Savings and Trust’ admission approaching administration accomplishments by the SEC?

Bitcoin Savings and Trust, which aloft a amazing 700,000 Bitcoins from investors, was answerable as a apparent boilerplate Ponzi scheme, with the barring that all investments were solicited, and declared allotment paid, in bitcoins. But it was notable for several reasons. First, it accustomed that the advance of Bitcoins could amuse the “investment of money” bender of the assay for an advance contract, contrarily accepted as the Howey test. Second, it approved that the SEC could conduct a flow-of-funds assay on the Bitcoin blockchain. While we could not authenticate area every Bitcoin came from or went, we could appearance that added Bitcoins were activity out to investors than came into Bitcoin Savings and Trust from any antecedent added than investors, thereby proving the Ponzi. Third, we did not booty the position that Bitcoin itself was a security. And finally, the case was cogent for the disgorgement approach avant-garde by the SEC, namely, that the disgorgement ordered by the cloister should reflect the affecting admission in the amount of Bitcoins from the time the investors handed their Bitcoins over to the defendant, to the date of the judgment. The Bitcoins the actor aloft from investors were account about $4.5 actor at the time, but the final acumen adjoin the actor was for added than $40 actor in disgorgement and penalties.

 

You were a founding affiliate of the SEC’s Distributed Ledger Technology Alive Group. What is the purpose of this group, and how does it appulse both investors and STOs?

With the added acceptance of blockchain technology, the SEC’s Distributed Ledger Technology Alive Accumulation was artlessly an accomplishment to alike both with added regulators and aural the SEC. It was important to ensure the assorted capacity and offices of the SEC were not alive at altercation with one another. The SEC has back congenital on the assignment of the accumulation with the conception of its Strategic Hub for Innovation and Banking Technology (FinHub), which engages in beat to both investors and issuers.

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You were amenable for investigations into assorted antecedent bread offerings (ICOs) for accessible violations of balance laws. What’s the best arrant abuse of balance law that you accept witnessed?

Without hesitation, it’s the ICO chic of 2017 and 2018. In February 2018, SEC Chairman Jay Clayton, testifying afore the Senate Committee on Banking, Housing, and Urban Affairs, abundantly said, “I accept every ICO I’ve apparent is a security.” A few months later, in a televised interview, Commissioner Robert Jackson said, “if you appetite to apperceive what our markets would attending like with no balance regulation, the acknowledgment is the ICO market.” On the whole, I accede with those sentiments. Best ICOs, during that period, were acceptable basal raises, with the basal aberration actuality that, in an ICO, one could acquirement shares in a company’s primary asset rather than shares in the aggregation itself. It’s not to say that best ICOs were frauds or not well-intentioned. However, there wasn’t abundant ambiguity about the actuality that they were unregistered balance offerings.

 

It’s accepted convenance for ICOs to block investments from USA investors. Nonetheless, those aforementioned blocked investors can again afterwards acquirement these tokens on cryptocurrency exchanges. Does this activity of initially blocking USA investors accumulate ICOs safe from SEC administration action?

The abbreviate acknowledgment is no. If an issuer accesses the U.S. basal markets, if it offers or sells balance in the U.S., anon or indirectly, the SEC will accept jurisdiction. The SEC has fabricated it bright that it is not acceptable to booty corrective or bisected measures to ahead one’s aegis badge alms (STO) from all-encompassing U.S. investors.

 

Do you accept that the SEC will become added proactive in advancing acknowledged activity and shutting bottomward able cryptocurrency exchanges?

Yes. Bringing administration accomplishments adjoin exchanges that abatement to appear into acquiescence for whatever reasons, admitting the SEC’s messaging in the space, makes faculty for the Administration Division. Not alone to accord teeth to above-mentioned statements by the Chairman, added commissioners, and assertive associates of chief management, but additionally because an administration activity adjoin an exchange, on the whole, should accept a greater programmatic appulse from a authoritative angle than an activity adjoin a distinct issuer.

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Do you accept any comments apropos the SEC’s best contempo accomplishments adjoin Telegram Accumulation Inc and its unregistered balance offering?

In my view, there are a brace of important takeaways. First, accompanying to your beforehand question, the Telegram case demonstrates the SEC will accompany beyond issuers of agenda assets or cryptocurrencies who activity or advertise those assets into the U.S., or contrarily admission the U.S. basal markets. Additionally, I ahead this could be an absorbing assay case for the account badge argument. Telegram has taken the position that, while the badge acquirement acceding for the Gram was a security, the badge itself is not. In its complaint adjoin Telegram, the SEC declared there was no aurora amid the Gram alms and the Gram token. Rather, the SEC alleged, the alms was a acceptable basal accession because, amid added things: the aggregation acclimated funds aloft for operations and to body out its ecosystem; there were no appurtenances or casework for which one ability use the Gram; and Gram purchasers had and – absent the emergency activity – would abide to accept a reasonable apprehension of administration in the company’s profits should it accomplish in architecture out the functionalities it promised. It will be absorbing to see how the facts and arguments advance on this affair as the activity progresses.

 

Could you allotment with us capacity apropos your accepted role with Seward & Kissel LLP?

I abutting Seward & Kissel in February 2019 and assignment carefully with several of the firm’s convenance areas in both New York and D.C., including the Government Administration and Centralized Investigations, Advance Management, and Blockchain and Cryptocurrency Groups. I spent the majority of my career at the SEC in the Administration Division’s Asset Administration Unit, and Seward & Kissel has one of the bigger and acclaimed Advance Administration practices in the U.S., alive with managers beyond all asset classes, including agenda assets. As a result, abundant of my accepted convenance centers on counseling our advance administration admirers on SEC and added authoritative examinations, investigations, and administration matters; centralized investigations; and agenda asset offerings. I accept additionally been asked to advance the Administration Committee for the Virtual Commodity Association in affiliation with its efforts to authorize a self-regulatory alignment (SRO) for cryptocurrency marketplaces.

 

What are some recommendations that you accept for companies that are because ablution an STO?

In my view, the best advance of activity is to appoint admonition with abysmal ability of both balance law and cryptocurrency. While some attorneys accept gotten up to acceleration on blockchain technology, abounding may be accomplishing their admirers a disservice because they are not as able-bodied abreast in the fundamentals of the balance laws.

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At what date should companies who are because ablution an STO acquaintance you or added acknowledged counsel?

The beforehand the bigger – alluringly afore any acquaintance with a regulator, and absolutely afore the activity or auction of any token.

 

Is there annihilation abroad that you would like to allotment with our audience? 

The SEC’s administration accomplishments adjoin ICO issuers acutely accept had an appulse on the market. However, Telegram, Block.one, and Kik were aloof three of the beyond ICOs from the 2017-2018 period. We should see added such cases in the advancing months or year. The SEC has brought administration accomplishments adjoin celebrity promoters of agenda assets, but I would apprehend a connected focus by the SEC on promoters and sellers. It’s account acquainted that one declared ambition of SEC administration accomplishments is to change the behavior of bazaar participants, so I ahead the SEC will abide to badge agenda asset exchanges and trading platforms. It’s the accustomed abutting footfall for the SEC afterwards the issuers and promoters and, as I mentioned, an befalling to accept a added appulse on the market. In a agnate vein, while a abundant cardinal of the SEC’s administration accomplishments in the amplitude accept circuitous declared Ponzi schemes or alms frauds, with a connected focus on exchanges and trading platforms, I would not be afraid if, not afore long, the SEC unearths added circuitous frauds involving bazaar abetment schemes or added bazaar abuses. However, alike well-intentioned bazaar participants can be swept up in this and can acquisition themselves the accountable of administration absorption as the SEC continues its efforts to admission industry acquiescence with balance laws and regulations. Seward & Kissel has been advising admirers in banking services, accumulated financing, and basal markets for added than 125 years. Our attorneys accept all-encompassing acquaintance with STOs and agenda asset offerings.

For added advice or to argue with acknowledged affairs amuse appointment Seward & Kissel LLP, or appointment their Twitter or LinkedIn page.

 

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