Collins Belton Profile picture
Attorney, Gamer, Wanderer. Not your lawyer (probably). “Oppression makes a wise man mad.”
Olímpico de Jesus Moreira Chaves Profile picture 1 subscribed
Mar 28, 2023 4 tweets 1 min read
“The only priority the Journal tested that has grown in importance in the past quarter-century is money, which was cited as very important by 43% in the new survey, up from 31% in 1998.” wsj.com/articles/ameri… It’s WSJ so of course you have to keep their std biases in mind & they concede their own change in methods could make comparative data less reliable, but still a wild stat. Other interesting data as well although I disagree with most of the voters’ theories on why & implications
Mar 27, 2023 22 tweets 8 min read
Well, I chose the wrong morning to start late.

Hard to TL;DR this one.

To try - CFTC Alleging:

- Unregistered deriv platform/broker
- Knowingly offered products to ineligible US
- Knowingly allowed crime/terrorism proceeds
- Cartel real
- IMO, more likely 2 come from DOJ First thing I'll note is that these are all allegations

That said, given the AML/sanction allegations, I don't think CFTC action is going to be the last we see from the U.S.

But like w BitMex, the effects of this may be more muted than some anticipate
Mar 22, 2023 8 tweets 3 min read
Hits just keep coming today.

"Based on discussions with the Staff, the Company believes these potential enforcement actions would relate to aspects of the Company’s spot market, staking service Coinbase Earn, Coinbase Prime and Coinbase Wallet." I'll be frank though, this is probably the suit we want to see litigated if a large CEX is going to litigate something. We knew the day was coming, let's hope @iampaulgrewal and @brian_armstrong are up to the task.
Mar 10, 2023 4 tweets 1 min read
As someone who has worked with SVB extensively, referred many clients and who ha friends who’ve worked at SVB, I genuinely think they’ll be ok and don’t wish them harm. However, I think it’s strange for people to admonish founders or investors encouraging founders to be cautious. Yes, bank runs are a confidence game and shouldn’t happen. And yes, barring something insane happening, the bank should be fine. And yes, SVB is a stalwart and, despite being a bank, arguably is a “bank with a heart” that fostered Silicon Valley. BUT…
Mar 9, 2023 4 tweets 2 min read
It’s kind of funny we’re ignoring KuCoin and the broader exchange implications in all this, but that is also impt to keep track of.

EG, all registered exchanges servicing NY residents, they are now technically offering unregistered securities according to the NYAG. What do? This is very bizarre considering the NY financial regulators not only have approved each of those exchanges but have had ample time to disclose any concerns about ETH status over the past five+ years with the POS shift happening.
Mar 9, 2023 5 tweets 1 min read
TL;DR - NYAG claiming eth is a security because of ICO, small number of developers driving most core dev, and proof of stake altered the incentive and profit expectations of holders. Ultimate boss battle time is approaching. That said, it’s unlikely KuCoin responds to this and I suspect NYAG wanted to put this argument out there to try to get it into a default judgment. Thats not as strong as something argued in court, but it ain’t nothing.
Feb 16, 2023 12 tweets 6 min read
OK, after an initial skim, there is ALOT going on and this may arguably be the most important SEC case brought to date for them to test MULTIPLE theories, but one of the biggest takeaways: they’re alleging everything in Luna eco - UST, Luna, wLuna & MIR assets were securities. Image Getting into the weeds now but this may have very far reaching implications for many projects. Despite Do’s obvious fraud and deep involvement that might distinguish some of the Luna eco, much of the behavior alleged to create the securities law issues are endemic in the industry
Jun 15, 2022 8 tweets 2 min read
Cannot stress how angry I am that the SEC and @GaryGensler + predecessors spent years harassing DeFi builders trying to move us away from opacity and literally missed all of these obvious risks that die hards have been screeching about for years. There’s no point in me getting more up in arms at the players or participants; humans exploit opportunities and I already accepted that these things wouldn’t end well without change.
Jun 14, 2022 6 tweets 2 min read
Astounding that this CEO scorned employees for rightly calling out what can only be described as biblical level mismanagement impacting thousands of people’s lives after the opportunities afforded by an historic money generating era for the business was completely squandered. I think it’s genuinely hard to overstate the level of mismanagement here. With so many other crypto failures recently, you can see how those entities get into those situations or can’t anticipate their future properly; this business has no excuse.
Jan 14, 2022 6 tweets 2 min read
It’s just amazing to me that regulators globally fumbled this so badly in part because of arrogant skepticism that something like DeFi could actually work and become an untamable hydra. Now each day it becomes increasingly hard to get people to color in the lines. As I referenced when I shifted my focus to pro bono and other matters, at this pt there are times where it feels almost negligent to counsel some of the things we must by virtue of today’s legal realities. It sometimes feels like telling a co to box opponents blind and bound.
Jan 7, 2022 10 tweets 3 min read
New SEC charges against 2018 ICO issuer CMCT.

Order isn’t surprising given fraud and broad public sale involving Americans, and agree w/ @DonnaRedel this is laughably late given the relatively small scale, but there are 3 pts worth mentioning imo.

Ahhh I’m threadinggg: 1. AFAIK, this is the 1st time community pools have been specifically called out. I’m kind of surprised it took them this long.

These groups are common in crypto and people need to be careful. Operators of these can be brokers and this may be a hook to get at some influencers.
Oct 4, 2021 10 tweets 2 min read
This highlights a particular challenge with squaring existing securities laws and the security needs of blockchain development that isn’t always clear.

Quick 🧵 to explain why and how this harms users. One challenge with @SECGov’s uneven application of Howey so far is that devs and counsel often are left struggling to determine what level of ongoing contribution the team can contribute before running the risk of being seen as providing “essential managerial efforts.”
Aug 17, 2021 14 tweets 3 min read
I guess now is as good of a time as any to announce that I’m officially retired from private practice as of last month to focus fully on crypto.

If you’re weird enough to care why some random lawyer dweeb left his job and what’s next, a few thoughts below. First, to be clear, I still will be keeping my firm up and running, but will no longer be taking paying clients for the most part.

Instead, I’d like to provide free legal advice to 1) 1st time founders and 2) underrepresented founders.
Aug 15, 2021 4 tweets 1 min read
Slowly starting to think the biggest losers of Web2 to Web3 won't be tradfi but will actually be gaming companies with valuable gaming/collectible/TCG IP that are watching multi-billion dollar opps mosey on by them with no sense of urgency. This isn't speculation either; I'm personally aware of some large gaming companies that have been poking around for 2-3 years now, but they never seem to have a cohesive strategy and have been in exploratory mode with a bunch of experiments w/ Web3 startups for years.
Aug 18, 2020 20 tweets 5 min read
Hot FUD: A landmark regulatory decision for #DeFi is likely coming that will serve as its DAO Report.

A few players are more vulnerable to regulatory action IMO: (1) Decentralization Flirts, (2) Permissioned Stablecoins and (3) wrapper/offchain custodians.

Thread (1/lot): First, some history & context.

Realize #DeFi projects pose some different legal issues for regulators compared to ICOs. One difference I'll focus on a lack of clearly identifiable issuer/operator, or relatedly, issuers/operators that intentionally relinquish control post-launch.
Oct 11, 2019 12 tweets 3 min read
So, as many predicted, looks like #Libra is all but DOA unless @davidmarcus and FB pull off a minor miracle.

I’m going to say something that will probably get me shunned by some - I think this should upset a lot of people. Not because the result isn’t great for crypto (it is)... but because the manner in which governments achieved this. I’ve been struggling to articulate just why I got this sinking feeling seeing this play out, but weirdly, seeing other “shadow” gov action curtailing innovation globally more recently has helped crystallize things for me.