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Key Takeaways

  • It was recently reported that the U.S. Securities and Exchange Commission (SEC) and the Financial Industry Regulatory Authority (FINRA) began probing Digital Asset Treasury companies (DATs), raising a variety of compliance and governance issues, including:
    • Preferential treatment of certain investors
    • Use of material nonpublic information (MNPI)
    • Inadequate internal controls and anti-money laundering (AML)