The U.S. SEC's Division of Corporation Finance has taken a landmark step by issuing a No Action Letter ("NAL") regarding the proposed 2Z token issuance by DoubleZero, stating that "based on the facts provided, the Division will not recommend enforcement action." This week, a crypto project sought forward-looking guidance on the legal status of its proposed token issuance and received a productive response. Previously, during Gary Gensler's tenure as chair of the SEC, the regulatory environment faced by crypto industry practitioners was characterized by a nearly entirely "retroactive enforcement" approach—projects that were originally invited to "sign up" ultimately received Wells Notices upon exiting the process. While this victory for crypto assets is largely credited to the SEC's shift in perspective and leadership, the legal team at DoubleZero clearly outlined the design of the token, which is also commendable. The SEC's No Action Letter indicates that the agency's staff does not...

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