Securities Enforcement. Corporate Investigations. Financial Regulation.

Independent analysis of the laws, regulations, investigations, and enforcement actions shaping modern financial markets.

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GESMER UPDEGROVE

BRAEDEN ANDERSON

Braeden is one of the top securities lawyers in the country and was recognized by Best Lawyers: Ones to Watch® in America in the Financial Services Regulation Law and Securities Regulation categories. This honor is awarded to only the top 2% of attorneys in the United States and is based on a comprehensive peer-review survey.

Braeden helped lead Gesmer Updegrove to recognition in The Legal 500 United States for Corporate Investigations & White Collar Crime, Tier 3, and Finance: Fintech, Tier 4.

Braeden is active in the U.S. securities enforcement community through Securities Docket, where he has served on the 2025 and 2026 Advisory Boards and contributed video commentary through the Weekly Update.

Braeden was named the #1 United States author in FinTech in Mondaq’s Spring 2025 Thought Leadership Awards, reflecting the national reach and influence of his writing on fintech, securities regulation, and digital asset policy.

Is Avalanche a Security?
K. Braeden Anderson K. Braeden Anderson

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.

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K. Braeden Anderson K. Braeden Anderson

The SEC Closes the Loop on Howey’s Application to Crypto

The SEC’s March 17, 2026 crypto guidance marks a turning point in digital asset regulation. By clarifying token classifications and, critically, when an investment contract begins and ends under Howey, the Commission introduces a lifecycle-based framework that brings long-awaited structure to the market. This article breaks down what the new interpretation means for crypto projects, investors, and regulatory strategy going forward.

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K. Braeden Anderson K. Braeden Anderson

Crenshaw’s Exit, Dissent, and the SEC’s Troubled Crypto Record

Acknowledging the value of dissent does not require suspending scrutiny. It is fair, and necessary, to ask whether the SEC during the prior administration, and Crenshaw in particular, demonstrated sufficient command of the crypto markets they sought to regulate, and whether the agency’s approach over the past several years meaningfully advanced investor protection or instead imposed avoidable costs through uncertainty and inconsistency.

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K. Braeden Anderson K. Braeden Anderson

Nasdaq’s Tokenization Proposal: A Careful Step Toward Modernizing Market Infrastructure

You can’t understand Nasdaq’s tokenization proposal by asking what it adds. You understand it by seeing what it refuses to change. Nasdaq’s tokenization rule filing with the U.S. Securities and Exchange Commission is one of the most meaningful attempts yet to introduce blockchain-based representations of securities into the existing U.S. market structure.

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Anderson Insights K. Braeden Anderson Anderson Insights K. Braeden Anderson

A Line in the Ledger: Federal Banking Agencies Issue Joint Statement on Crypto-Asset Safekeeping

On July 14, 2025, the OCC, Federal Reserve Board, and FDIC quietly issued a joint statement that may one day be remembered as a foundational moment in the formal convergence of traditional banking oversight and crypto infrastructure. The Statement on Crypto-Asset Safekeeping Risk Management sends a clear signal: if your institution intends to hold digital assets for clients, the expectations are not experimental — they are bank-grade.

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