Securities Enforcement. Corporate Investigations. Financial Regulation.
Independent analysis of the laws, regulations, investigations, and enforcement actions shaping modern financial markets.
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.
SEC Moves Toward Rescinding “No-Deny” Settlement Policy
The White House is reviewing the SEC’s plan to rescind its long-standing “no admit, no deny” settlement policy, often criticized as a “gag rule.” The proposal, listed by OIRA as “Rescission of Policy Regarding Denials in Settlements of Enforcement Actions,” could reshape SEC enforcement settlements by allowing companies and individuals to resolve cases without being barred from publicly disputing the allegations.
Code Without a License? The SEC Signals a Path for Crypto Interfaces Outside Broker Registration
The SEC has drawn a new line between software and securities intermediaries. This analysis examines the implications for DeFi interfaces, transaction-based fees, and evolving market structure.
The SEC’s Bail-In Position Prioritizes Function Over Formalism
The SEC’s no-action letter to the Bank of England signals a shift in how U.S. securities law applies to cross-border bank resolution. By allowing reliance on Section 3(a)(9) in bail-in scenarios, the SEC is prioritizing market stability over formal registration requirements. Chairman Paul Atkins’ call for broader rulemaking suggests a potential exemption for securities issued during regulatory bail-ins. This development has significant implications for asset managers, broker-dealers, and institutions with exposure to foreign banks. It reflects a more pragmatic approach to global financial regulation and highlights the tension between investor protection and systemic stability in crisis scenarios.
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.
Rule 15c2-11 and the Cost of Regulatory Drift
The SEC’s proposed amendments to Rule 15c2-11 mark a long-overdue correction to years of regulatory uncertainty affecting fixed-income markets. By narrowing the rule’s scope to equity securities, the Commission is realigning its application with market reality and prior intent. This article breaks down what went wrong, why it matters, and what the proposal signals for future rulemaking and regulatory discipline.