This GT Advisory considers the application of state unclaimed property laws to cryptocurrencies, and the potential implications and challenges of such application for both industry participants and state unclaimed property administrators.

The use of blockchain technology and the issuance of cryptocurrencies have grown considerably in recent years, inviting heightened scrutiny and regulation. While federal securities, tax, and other financial services regulatory agencies, such as the SEC, the IRS, state securities commissioners and others, have begun applying their rules and regulations to cryptocurrency businesses, the cryptocurrency industry has not yet faced significant enforcement from state unclaimed property administrators.

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Photo of Brooke E. Condran Brooke E. Condran

Brooke Condran focuses her practice on a broad range of transactional matters, including mergers and acquisitions, new entity formation and early stage company representation, SEC compliance and reporting, and general corporate governance and compliance. Brooke also has experience counseling clients on matters involving…

Brooke Condran focuses her practice on a broad range of transactional matters, including mergers and acquisitions, new entity formation and early stage company representation, SEC compliance and reporting, and general corporate governance and compliance. Brooke also has experience counseling clients on matters involving unclaimed property, including reporting requirements, the claiming process, and voluntary compliance programs.

Photo of Marc J. Musyl Marc J. Musyl

Marc J. Musyl has wide-ranging experience representing public and private business clients in dispositions, mergers and acquisitions of all sorts as well as contracting, licensing, corporate governance and compliance. He is experienced in capital markets transactions including public and private offerings of equity…

Marc J. Musyl has wide-ranging experience representing public and private business clients in dispositions, mergers and acquisitions of all sorts as well as contracting, licensing, corporate governance and compliance. He is experienced in capital markets transactions including public and private offerings of equity and debt. He has broad industry experience specifically including financial services (where he has represented banks, clearing firms, brokerage firms, investment advisors and investment banks); energy; mining and natural resources; agriculture; aerospace; bioscience; manufacturing; and computer software. In addition, Marc chairs the firm’s Unclaimed Property Practice Group.

Photo of Steven M. Felsenstein Steven M. Felsenstein

Steven M. Felsenstein is Co-Chair of the Investment Management Practice and Co-Chair of the Financial Regulatory and Compliance Practice and focuses his practice on serving clients involved in financial services industries. He advises investment companies registered under the Investment Company Act of 1940…

Steven M. Felsenstein is Co-Chair of the Investment Management Practice and Co-Chair of the Financial Regulatory and Compliance Practice and focuses his practice on serving clients involved in financial services industries. He advises investment companies registered under the Investment Company Act of 1940, investment advisers registered under the Investment Advisers Act, and other administrators and service providers involved in the industry. Steven also represents broker-dealers and transfer agents registered under the Securities Exchange Act of 1934, and issuers of securities under the Securities Act of 1933. Steven represents clients in connection with administrative proceedings conducted by the SEC and FINRA, and participates in related actions. Steven’s prior practice includes experience as a staff member in the Division of Corporation Finance and as a Branch Chief in the Division of Investment Management at the U.S. Securities & Exchange Commission.