Not So Fast: Why Compliance Can’t Ignore Digital Assets Even If the Investment Team Does

Registered investment advisers – even those that do not provide advice about digital assets – are increasingly becoming aware of the need to take digital assets into account when drafting and implementing their codes of ethics. This is a direct result of the increasing frequency with which an adviser’s access persons may want to make personal investments in digital assets.

In addition to providing a brief background on the personal transaction reporting requirements of the code of ethics rule, we discuss different types of digital assets, the securities law analysis that is currently applied to digital assets, and the resulting application of the code of ethics rule to digital assets.

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