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Matthew Orso

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Matt is a skilled advocate for clients subject to regulatory oversight, including financial services companies. He provides guidance by developing informed strategies for investigations, enforcement matters, compliance, and litigation.

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On August 9, the Securities and Exchange Commission (SEC) sent a letter to U.S. District Judge Analisa Torres requesting leave to file an interlocutory appeal in SEC v. Ripple Labs, Inc. as to the two adverse liability determinations in her July 13, 2023 order. That order granted partial summary judgment in Ripple Labs’ favor regarding the sale of its XRP token. As we previously discussed here, the court held in deciding cross motions for summary judgment that defendants’ “programmatic” offers and sales to XRP buyers over crypto asset trading platforms and Ripple’s “other distributions” in exchange for labor and services did not involve the offer or sale of securities under the U.S. Supreme Court’s decision in SEC v. W.J. Howey Co.

On August 2, the Federal Financial Institutions Examination Council (FFIEC) announced updates to certain sections and examination procedures in the FFIEC Bank Secrecy Act/Anti-Money Laundering Examination Manual (Manual). The Manual instructs examiners on how to assess a bank’s anti-money laundering/countering the financing of terrorism (AML/CFT) program and its compliance with other AML/CFT regulatory requirements. The FFIEC cautions that the updates should not be seen as new instructions or an increased focus on certain areas, but instead as offering further transparency into the examination process and supporting risk-focused examination work.

On June 1, House Financial Services Committee Chair Patrick McHenry (R-NC) and

House Committee on Agriculture Chair Glenn “GT” Thompson (R-PA) released a discussion draft of legislation intended to fill gaps in digital asset regulation and provide a framework that will provide the crypto industry and consumers with some much-needed certainty. The proposal includes a…