Cryptocurrency Licensing & Regulatory Filings

WilmerHale secures federal and state licenses and regulatory approvals for cryptocurrency and blockchain businesses, leveraging deep expertise in securities, futures, and derivatives regulation.

Federal Agency Approvals & Registrations

The firm has extensive experience obtaining approvals from major financial regulators including the CFTC, SEC, FINRA, FinCEN, and OFAC. WilmerHale has successfully navigated complex regulatory frameworks to secure licenses for cryptocurrency exchanges, trading platforms, stablecoin issuers, and blockchain-based financial services.

Representative Experience

CFTC Approvals

• Advised on the formation of the first CFTC-approved trading platform for bitcoin currency swaps, involving creation of a proprietary benchmark bitcoin index for objectively gauging the worth of swap contracts settled in dollars
• Represented digital asset trading platform offering derivative products for bitcoin and other digital currencies in CFTC regulatory matters

State Licensing

• Obtained NYDFS limited purpose trust company charter for a stablecoin issuer
• Money transmitter licensing across multiple state jurisdictions

Broker-Dealer Registration

• Secured FINRA approval for one of the first broker-dealers to use blockchain technology to effect traditional securities transactions
• Represented technology companies tokenizing traditional securities through broker-dealer registrations

Money Services Business & MSB Licensing Advising virtual currency exchanges and blockchain companies on federal and state compliance and licensing obligations for entities defined as money services businesses or money transmitters under FinCEN regulations.

Ongoing Regulatory Relationships

WilmerHale maintains strong relationships with key regulators including SEC, CFTC, FINRA, FinCEN, OFAC, and state securities and banking authorities. The firm provides ongoing regulatory guidance to help cryptocurrency businesses navigate evolving compliance requirements and maintain good standing with supervisory agencies.

Why Choose WilmerHale

Since the inception of blockchain and cryptocurrency, WilmerHale has provided strategic regulatory counsel to leading companies in the ecosystem. The firm combines deep roots in securities, futures and derivatives regulation with technical insight into blockchain technology to deliver informed, actionable guidance on novel licensing and compliance challenges.