Tag Archives: Benjamin Neaderland

SEC Chair Atkins Unveils “Project Crypto” to Modernize US Securities Regulation

by Jeremy Moorehouse, Zachary Goldman, Benjamin Neaderland, and Matthew Beville

Left to right: Jeremy Moorehouse, Zachary Goldman, Benjamin Neaderland, and Matthew Beville (photos courtesy of WilmerHale)

Introduction

On July 31, 2025, SEC Chairman Paul Atkins delivered a major policy address at the America First Policy Institute in Washington, D.C., unveiling “Project Crypto”—a Commission-wide initiative to modernize securities regulation in support of President Trump’s vision of the United States as the “crypto capital of the world.” Framing the moment as a defining opportunity for American leadership in digital finance, Atkins outlined a regulatory agenda focused on integrating “on-chain” (on blockchain technology) software systems into US markets, enabling decentralized finance, and launching a new “innovation exemption” to accelerate the commercial deployment of novel technologies. His remarks signal a significant shift toward a more flexible regulatory posture that could shape the future of the US digital asset market for years to come.

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Recent Exemptions From Rule 206(4)-5 Demonstrate the Importance of Strong Compliance Policies and Quick Corrective Action

by Benjamin Neaderland, Joseph M. Toner, and Thomas K. Bredar

Author photographs

From left to right: Benjamin Neaderland, Joseph M. Toner, and Thomas K. Bredar. (Photos courtesy of Wilmer Cutler Pickering Hale & Dorr LLP)

Recently, the Securities and Exchange Commission (SEC) has demonstrated its willingness to largely forgo the strict consequences of Investment Advisers Act Rule 206(4)-5 (the “Pay-to-Play Rule”) in circumstances where investment advisers can demonstrate that they have effective compliance policies and took action when confronted with a potential violation. These recent exemptive orders are the first such orders since 2020.

The Pay-to-Play Rule is intended to deter investment advisers, and their covered associates, from using campaign contributions to exert improper influence over existing or prospective investments by public sector clients. Violations of the Pay-to-Play Rule can lead to fines and prohibitions on investment advisers receiving any compensation from a government entity for two years following the date of the violative contribution.[1]
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