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Even After SEC Guidance, Compliance Blind Spot Remains for Cryptocurrency Trading

Legaltech News

21 Sep 2017

Jay G. Baris addresses the investment code of ethics and provides guidance on how to follow it with regard to cryptocurrency in the Legaltech News article “Even After SEC Guidance, Compliance Blind Spot Remains for Cryptocurrency Trading.”

The purpose is to prevent covered employees “from improperly benefiting from their position or from using investment knowledge for their own benefit or to the detriment of their clients.”  Every employee governed by the code “should list every transaction and the amount of each security,” he said.

In the same article, Joshua Ashley Klayman advises how to mitigate the noncompliance risk. “An investment adviser should consider how its code of ethics should address cryptocurrencies, particularly if the investment adviser is trading cryptocurrencies or if [its employees] are trading it for their personal accounts,” she said.

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