Blazing new trails in crypto regulatory and compliance, time and again
During his time at the SEC, Michael worked as investment management counsel for two SEC commissioners and in the Office of Chief Counsel, Division of Investment Management, and served on the first internal working group on blockchain technology and cryptocurrency. That insight and experience inform how he guides cryptocurrency clients through the federal securities laws and complex regulatory issues raised by cryptocurrency products, digital asset sales and digital securities. Clients trust Michael’s counsel and perspective on regulatory considerations and compliance strategies, and his broad knowledge helps companies in this space address the evolving challenges and opportunities in these rapidly developing areas. His extensive subject matter knowledge and reputation with regulators and across the industry are enormously helpful to clients.
In 2020, Michael secured SEC Staff no-action relief for a client — a milestone for the client and the broader blockchain industry. This achievement reflected a significant shift in how blockchain innovators interact with regulatory authorities. As only the third and final no-action letter granted in the blockchain sector, it carried considerable weight, especially since the SEC determined that the client’s blockchain digital asset did not qualify as a security. Notably, this was the only instance in which the SEC permitted a client’s digital asset to be freely transferable off the client’s platform. Michael’s ability to shepherd his client through this uncharted regulatory territory highlights his capacity to help clients address novel challenges and shape the evolving legal landscape.
Guiding asset managers through complex regulatory challenges and strategic growth
Michael regularly guides clients through SEC examinations and enforcement investigations, helping them develop and implement effective compliance programs. His experience also extends to structuring and governance issues, strategic transactions, and the launch and operation of both registered and private investment products.
In addition to his advisory work, Michael is actively involved in policy discussions and rulemakings that impact the asset management sector, and he frequently shares his insights at industry events and through published articles on regulatory developments and best practices.
