For some ideas on necessary steps to move forward, see: .

One interesting aspect of this story is that the firm used non-US influencers to market to non-US customers. Perhaps the firm thought (wrongly) that doing so might take it out of the jurisdiction of the US regulators.  

The Commissioners showed grace in their farewell statement to Chair Gensler. The list of achievements that the Commissioners (two Republicans) cited, however, failed to mention the many rule adoptions under litigation or the flawed clearing mandate. That might mean they are not supportive of those rule adoptions. Or it could mean nothing (but that would be a less interesting comment).  

While SEC Chair Gensler did little to prepare for the inevitable legalization of cryptocurrencies, Commissioner Peirce wrote well-reasoned dissents and offered important ideas (like the Safe Harbor) which should help lay the foundation for her new role. Her approach to regulation is everything that has been missing: respect for the rule of law, open-mindedness, concern for the details, modesty and a genuine sense of humor. There is not a better person to lead this regulatory effort.

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