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MoFo's Financial Markets & Innovation #9

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Please see below for this week’s Financial Markets & Innovation Weekly Update from Morrison Foerster, tracking how emerging...

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<p>We are Morrison Foerster — a global firm of exceptional credentials. Our clients include some of the largest financial institutions, investment banks, and Fortune 100, technology, and life sciences companies. Our lawyers are committed to achieving innovative and business-minded results for our clients, while preserving the differences that make us stronger.</p><p>Because of the generality of this update, the information provided herein may not be applicable in all situations and should not be acted upon without specific legal advice based on particular situations. Prior results do not guarantee a similar outcome.</p>

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<p>Please see below for this week’s Financial Markets & Innovation Weekly Update from Morrison Foerster, tracking how emerging technologies are reshaping financial markets and how U.S. and global regulators are responding. Covering developments across digital assets, prediction markets, artificial intelligence, and next-generation trading infrastructure, this update highlights key regulatory actions, enforcement activity, policy signals, and related market structure implications. </p><h4>SEC Trading and Markets Staff Provides Conditional No-Action Relief for Certain Crypto Trading Interfaces</h4><p>On April 13, staff in the SEC’s Division of Trading and Markets <a href="https://www.sec.gov/newsroom/speeches-statements/staff-statement-regarding-broker-dealer-registration-certain-user-interfaces-utilized-prepare-staff-statement-regarding-broker-dealer-registration-certain-user-interfaces-utilized" target="_blank">issued</a> a Staff Statement providing conditional, five-year no-action relief from broker-dealer registration under Section 15 of the Securities Exchange Act of 1934 for certain Covered User Interface Providers offering crypto asset services. The relief applies to certain crypto trading interfaces, such as non-custodial wallets or front ends to blockchain-enabled software applications, provided they do not take custody of customer assets, execute trades on a user’s behalf, or provide investment advice.</p><h4>Senator Blumenthal Requests Information on National Security Trading from Large Prediction Market</h4><p>On April 9, Senator Blumenthal sent a <a href="https://www.blumenthal.senate.gov/imo/media/doc/2026-04-09_letter_polymarket-national_security.pdf" target="_blank">letter</a> to the CEO of Polymarket regarding potential insider trading on their prediction markets. The letter alleges that new users placed large and specific bets prior to significant action in Venezuela and Iran earlier this year, which Blumenthal believes may indicate some users are trading on national security secrets. Since the actions in Venezuela and Iran, Polymarket has announced additional rules to combat the use of confidential information in trading. The Senator requests additional information on death wagers, national security information, and insider trading by April 24, 2026. </p><h4>Update on State Prediction Market Treatment</h4><p>Following the CFTC-DOJ joint filing against Arizona, Connecticut, and Illinois last week, discussed in last week’s <a href="/resources/insights/260410-mofo-s-financial-markets-innovation?utm_source=chatgpt.com" target="_self">Financial Markets & Innovation Weekly Update from Morrison Foerster</a>, the CFTC <a href="https://www.cftc.gov/PressRoom/PressReleases/9208-26" target="_blank">filed</a> a motion on April 9 requesting the halt of Arizona’s application of state laws to CFTC-registered prediction markets. The U.S. District Court of Arizona <a href="https://www.cftc.gov/media/13721/ENFArizonaTemporaryRestrainingOrder041026/download" target="_blank">granted</a> their request for a temporary restraining order on April 10. In the same vein, Kalshi filed suit against Montana officials on April 13 for their application of state gambling laws to the CFTC-registered prediction market. This recent suit against Montana comes after multiple cease-and-desist letters and an agreement between Kalshi attorneys and Montana regulators. </p><h4>CFTC Announces Members of Innovation Task Force<strong> </strong></h4><p>On April 10, the CFTC <a href="https://www.cftc.gov/PressRoom/PressReleases/9210-26" target="_blank">announced</a> members of its Innovation Task Force, which include attorneys from large law firms, consultants, and CFTC staff members. The Innovation Task Force will focus on regulatory clarity for digital assets, AI, and prediction markets, and will be led by Michael K. Passalacqua.</p>

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<p>Ryne Miller is a partner in the firm’s Financial Services Group, advising global trading and markets businesses, financial institutions, and fintech companies on complex regulatory, governance, investigative, and transactional matters. He is widely sought for his experience across traditional and emerging markets, including commodities, derivatives, securities, digital assets, and prediction markets. Ryne delivers clear, commercially focused guidance to help clients achieve strategic objectives and is valued for his longstanding relationships with market participants and regulators across the trading and markets industry.<br></p><p>Clients rely on Ryne’s deep experience with the regulatory and enforcement programs of the Commodity Futures Trading Commission (CFTC), Securities and Exchange Commission, FINRA, National Futures Association, FinCEN, Department of Justice, and other federal and state regulators. Executives consistently seek his judgment on high-stakes matters involving investigations, governance, strategic relationships and negotiations, and crisis and incident response.<br></p><p>Ryne is a frequent speaker at trading and markets industry events, a guest lecturer at leading U.S. law and business schools, and has testified before Congress on digital asset market structure regulation. He has also participated in a CFTC roundtable on the evolution of U.S. derivatives market structure.<br></p><p>Before joining Morrison Foerster, Ryne served as chair of the Commodities, Futures & Derivatives Group and co-chair of the Fintech, Crypto, Trading & Markets Group at another leading law firm. Earlier in his career, he was a New York-based partner and co-head of the Commodities and Derivatives practice at an Am Law 10 firm, served as legal counsel to a former chairman of the CFTC, and was general counsel to a U.S. financial services and digital assets business.</p>

Ryne Miller

Partner

<p>Trevor Levine is a partner in the firm’s Financial Services Group, where he advises financial services firms and digital asset companies on turning regulatory complexity into commercial opportunity. He advises clients operating at the intersection of finance and technology, guiding them through rapidly evolving legal frameworks while supporting growth, innovation, and market expansion.<br></p><p>Trevor advises exchanges, intermediaries, market participants, and technology companies on issues arising under the Commodity Exchange Act, including representing clients seeking to register with the CFTC and NFA. He also helps clients navigate federal securities laws, FINRA rules, and state money transmission laws. Clients trust Trevor to guide them through regulatory inquiries while helping them design, launch, and operationalize compliant financial products and structures, including advising on applicable registration and licensing processes.<br></p><p>Before joining Morrison Foerster, Trevor served as general counsel to a brokerage firm focused on the digital asset, Bitcoin mining, and data center sectors. In that role, he oversaw legal and regulatory matters across multiple regulated subsidiaries, including a FINRA-registered broker-dealer, an NFA-registered introducing broker, and a New York BitLicensee. He also previously worked in-house at a large, regulated digital asset trading platform, where he advised on the acquisition and maintenance of CFTC, SEC, and state licenses.<br></p><p>Earlier in his career, Trevor practiced at two Am Law 100 firms, advising clients on a range of regulatory matters, including CFTC inquiries related to reporting obligations and market activity, as well as state and federal regulatory issues involving consumer lending practices. He has also advised companies on the development and launch of blockchain networks, cryptocurrencies, and decentralized applications.</p>

Trevor Levine

<p>Val Dahiya is a partner in the firm’s Broker-Dealer Compliance + Regulation and Capital Markets practice groups, Co-Head of its Securities + Derivatives Regulatory Solutions team, and Co-Lead of the firm’s Digital Assets practice within the Fintech Group.</p><p>Val advises financial services clients on complex compliance, regulatory, and transactional matters arising under U.S. Securities and Exchange Commission (SEC) and Financial Institution Regulatory (FINRA) jurisdiction. She has nearly two decades of experience in advising on securities market infrastructure, including over 10 years of work history at the SEC and three years at FINRA.</p><h4 dir="ltr">Professional Experience: SEC and FINRA </h4><p>Prior to joining Morrison Foerster, Val chaired the securities trading and markets practice and served as office managing partner at another international law firm. Before that, she served as the Washington, D.C. Branch Chief in the Office of Trading Practices in the Division of Trading and Markets at the SEC, where she provided analysis and recommendations on complex legal and policy issues related to the securities industry, including the application of Exchange Act rules and regulations to emerging areas such as cryptocurrencies and digital assets. Val’s counsel was essential in shaping SEC policies and ensuring their consistent application across the evolving financial landscape. </p><p>Prior to this, Val’s responsibilities as Special Counsel in the Division of Trading and Markets included providing essential guidance on securities regulation compliance, including the Commission’s financial integrity and regulatory programs for broker-dealers and securities exchanges. Val also worked closely with the Divisions Office of Market Supervision reviewing self-regulatory organization (SRO) rule filings.   </p><p>In her capacity as Attorney/Senior Counsel in the Division of Examinations, Broker-Dealer Group, Val led comprehensive examinations and inspections of broker-dealers and dually registered entities, ensuring compliance with federal securities laws and SRO rules. Her responsibilities also extended to preparing enforcement referral memoranda and assisting the Enforcement Division in complex trading cases. </p><p>While at the SEC, Val also worked extensively on issues related to trading practices, including market making, ETFs, direct market or sponsored access, when-issued securities, and trading in the grey markets.</p><p>Prior to her tenure at the SEC, Val worked at FINRA (formerly NASD), where she conducted reviews and investigations of broker-dealer activities, identified violations of relevant regulations, and made disciplinary recommendations. Her work at FINRA involved analyzing trading activity for irregularities and patterns indicating violative conduct.</p><p>Collectively, this experience informs Val’s counsel on the highly complex regulatory issues associated with broker-dealer, transfer agent, clearing agency, exchange and Alternative Trading System (ATS) operations, registration requirements, and compliance.</p><h4 dir="ltr">Capabilities</h4><p>Val also advises clients in the distributed ledger technology space that are seeking to understand the potential securities regulatory implications. Her practice ranges from product counseling all the way through to counseling on complex compliance and regulatory issues.</p><p>Other areas Val is particularly well qualified to advise on include:</p><ul dir="ltr"><li dir="ltr">broker-dealer compliance issues relating to Regulations ATS, NMS, M, SCI, and SHO, as well Rules 15c2-11, 15c3-5, and 15c3-3;</li><li dir="ltr">Regulation BI and standard of care issues;</li><li dir="ltr">books-and-records requirements;</li><li dir="ltr">large trader and position reporting;</li><li dir="ltr">forex trading;</li><li dir="ltr">market access and other electronic trading issues;</li><li dir="ltr">information barriers and insider trading;</li><li dir="ltr">soft dollars and commission sharing arrangements;</li><li dir="ltr">the net capital and customer protection rules; and</li><li dir="ltr">cybersecurity and data protection issues.</li></ul><h4 dir="ltr">Leadership</h4><p>Val is a member of the Nasdaq Exchange Review Council for each of Nasdaq’s six exchanges. Prior to joining Morrison Foerster, Val served as office managing partner at another international law firm.  </p>

Val Dahiya

Co-Head of Securities + Derivatives Regulatory Solutions

<p>Alex, co-lead of the firm's Digital Assets practice, advises banks and technology companies on a wide range of regulatory and supervisory matters, including new bank charters, enforcement and examination issues, stablecoin issuance and facilitation, bank-Fintech partnerships, and digital assets. Her experience includes advising on digital asset product development and agentic commerce issues, supervisory examination remediation, regulatory due diligence and compliance, and bankruptcy. With experience serving in senior FDIC roles and an extensive background counseling the largest financial institutions and technology companies in the U.S., Alex offers clients a broad market perspective, practical solutions, and a deep appreciation for the nuances of today’s regulatory landscape.</p><p>Alex served in various leadership roles at the FDIC. As an associate director, she was the lead regulatory policy expert for the Division of Complex Institution Supervision and Resolution, focusing on U.S. and global regulatory issues affecting the largest and most systemically important banking institutions. She worked closely with Federal Reserve staff on resolution plan rules, related guidance, and feedback letters, and engaged directly with banks and trade associations.</p><p>Alex is widely respected for her thought leadership, making live appearances on Bloomberg’s The Close and speaking on current banking developments domestically and abroad. She has been quoted extensively, including in <em>American Banker, Bloomberg Law, The Washington Post, The Wall Street Journal, OpenBanker, Law360, Coindesk,</em> and <em>Risk</em>. Alex also provides technical assistance to congressional staff on digital asset legislation.</p><p>She earned her J.D. from Georgetown University Law Center and received her B.A. cum laude from Williams College.</p><h4>Representative Experience</h4><ul><li>Global Fintech and Stablecoin Issuers: Advise on stablecoin issuance and compliance strategy, new products, provide policy and regulatory advice</li></ul><ul><li>Global Cryptocurrency Exchange: Advise on impacts of regulatory proposals; provide policy and regulatory on various bank partnerships </li><li>Leading Digital Asset Infrastructure Company: Advising on regulatory and policy matters following GENIUS enactment </li><li>Advise de novo bank charter applicant before U.S. banking regulators</li><li>Advise large/mid-size banks and technology companies in preparation for supervisory examinations, responding to MOUs and public enforcement actions before state and federal banking regulators</li><li>Representation of fifty state bankers associations and DC on amici brief in the U.S. Court of Appeals for the Tenth Circuit contesting Colorado’s legislative efforts to opt-out of DIDMCA</li><li>Advise nationwide money transmission/payments company and Fintech providers on regulatory compliance and licensing issues, including issues involving pass-through insurance, brokered deposits, and marketing representations</li><li>Represent banking institutions and technology companies on regulatory and transactional issues involving their banking as a service platform, including deposit account onboarding/enhanced due diligence, third-party risk management issues, and due diligence frameworks involving the sponsorship of merchant acquirer/cryptocurrency exchange programs</li><li>Advise banks on resolution planning requirements under Title I of the Dodd-Frank Act and the FDIC IDI Rule, including related supervisory engagement</li><li>Advised one of the largest global technology cloud service providers opposite federal regulators in their role as a bank service provider</li><li>Advised a leading global payments and enterprise blockchain company on new product launch, bankruptcy issues, and regulatory due diligence</li></ul>

Alexandra Barrage

Digital Assets + Blockchain

Fintech

Financial Services