Compliance and Governance for Crypto-Asset Managers

Jason Scharfman
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Jason Scharfman: Corgentum Consulting, LLC

Chapter Chapter 4 in Cryptocurrency Compliance and Operations, 2022, pp 73-89 from Springer

Abstract: Abstract This chapter provides an overview of compliance and governance considerations for crypto-asset managers. We begin this chapter by distinguishing the concepts of mandatory and voluntary compliance. Next, we discuss the extent to which crypto funds that are not registered with financial regulators may still be subjected to regulatory compliance oversight. We then proceed to analyze in-house versus outsourced compliance functions. As part of this conversation, we consider the requirements in place for in-house compliance resources at a crypto fund. We then proceed to discuss the development of a crypto fund’s compliance manual and Code of Ethics. As part of this conversation, we discuss the concept of crypto trading compliance including crypto-related insider trading risks. Compliance training is next discussed including an overview of firm-wide compliance training as well as department-specific and issue-specific compliance training. Other topics discussed in this chapter include compliance testing, surveillance and crypto governance mechanisms ranging from the board of directors and the role of the Limited Partner Advisory Committee (LPAC).

Keywords: Crypto compliance; Regulatory compliance; Securities and Exchange Commission (SEC); Investment Adviser; Cryptocurrency governance; Chief Compliance Officer (CCO); A Limited Partner Advisory Committee (LPAC) (search for similar items in EconPapers)
Date: 2022
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Persistent link: https://EconPapers.repec.org/RePEc:spr:sprchp:978-3-030-88000-2_4

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DOI: 10.1007/978-3-030-88000-2_4

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