BRAEDEN ANDERSON
Welcome to Anderson Insights.
We provide authoritative analysis on securities and commodities regulation, SEC and FINRA enforcement, and legal developments affecting crypto, digital assets, fintech, and financial services, authored by Braeden Anderson.
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Is Avalanche a Security?
Avalanche sits at the center of the SEC’s evolving crypto framework, and as a securities law nerd, this is the kind of debate I genuinely enjoy. With the agency’s 2026 interpretation recognizing “digital commodities” and Ava Labs advancing a functional, infrastructure-first approach, the analysis is becoming more precise. This piece explores whether AVAX fits within securities law, how the SEC’s latest guidance reshapes the landscape, and where automation, liability, and real-world network activity still leave meaningful open questions.
The SEC’s New Enforcement Manual Signals a Procedural Reset in Securities Enforcement
On February 24, 2026, the SEC’s Division of Enforcement published a revised Enforcement Manual. This article is a clean-room, original discussion of the press release and the 2026 Enforcement Manual. It is also meant to sit naturally inside the enforcement “throughline” I have been building on Anderson Insights: the idea that enforcement outcomes are increasingly driven by (i) data and surveillance sophistication, (ii) procedural architecture, and (iii) the downstream consequences of resolutions, often more than the headline penalty itself.
About the Author - Braeden Anderson is a partner at Gesmer Updegrove LLP, where he leads the Securities Regulatory and Enforcement and Digital Assets practice areas. Prior experience includes roles at Robinhood Markets, Inc., Kirkland & Ellis LLP, Sidley Austin LLP, Anderson P.C., and FINRA. He’s been nationally recognized by Best Lawyers in America: Ones to Watch® for Financial Services and Securities Regulation, and listed in Marquis Who’s Who in America for contributions to law and public service.