#160 - DoubleZero's Historic No-action Letter From The U.S. Securities And Exchange Commission Law Of Code podcast

Content provided by Jacob Robinson. All podcast content including episodes, graphics, and podcast descriptions are uploaded and provided directly by Jacob Robinson or their podcast platform partner. If you believe someone is using your copyrighted work without your permission, you can follow the process outlined here https://podcastplayer.com/legal.

Law of Code »
#160 - DoubleZero's historic no-action letter from the U.S. Securities and Exchange Commission

3d ago 31:08

MP3•Episode home

In this episode, Jacob is joined by DoubleZero’s General Counsel, Mari Tomunen, and Cooley’s Connor Tweardy to unpack the U.S. SEC’s Division of Corporation Finance’s landmark no-action letter to DoubleZero, a decentralized physical infrastructure (DePIN) project that became the first crypto initiative in over five years to secure such relief.

Timestamps:

➡️ 01:20 – Why DoubleZero engaged with the SEC

➡️ 03:00 – Communicating DePIN to regulators

➡️ 04:40 – Making decentralization “lawyer-friendly”

➡️ 07:00 – Why the token's status was crucial

➡️ 08:20 – Compliance by design

➡️ 10:00 – The DoubleZero Foundation’s role

➡️ 11:45 – How the SEC evaluated “managerial efforts”

➡️ 13:20 – How an international footprint shaped dialogue with regulators

➡️ 15:30 – Lessons for other projects

➡️ 18:00 – The SEC’s “efforts balancing” test

➡️ 22:00 – Why discretionary control and passive income models raise red flags

➡️ 26:00 – Designing compliance into your protocol

➡️ 30:00 – Advice for teams pursuing regulatory clarity

Sponsor: Day One Law. ⁠⁠ This episode is brought to you by ⁠⁠⁠Day One Law⁠, a boutique law firm helping crypto startups navigate complex legal challenges. Subscribe to ⁠⁠⁠Day One’s free monthly newsletter⁠⁠⁠ for legal and regulatory updates.

Resources:

No-Action Letter: https://www.sec.gov/files/corpfin/no-action/doublezero-final-conformed-092625.pdf

Cooley LLP's blog post: https://www.cooley.com/news/coverage/2025/2025-09-29-doublezero-secures-no-action-relief-from-sec

Disclaimer:

The information in this podcast is provided for educational and informational purposes only and should not be construed as legal advice. Listening to this episode or contacting the guests does not create an attorney-client relationship. For advice regarding your specific situation, please consult your own legal counsel.

159 episodes

#Jacob Robinson #Tech #Digital Asset