Law of Code #160 - DoubleZero's historic no-action letter from the U.S. Securities and Exchange Commission
Nov 9, 2025
Mari Tomunen, General Counsel at DoubleZero, and Connor Tweardy, a Cooley LLP attorney, delve into the groundbreaking no-action letter from the SEC. They discuss the significance of compliance-by-design and how DoubleZero communicated its decentralized infrastructure to regulators. The guests share insights on the importance of token timing, the foundation's non-investment stance, and the SEC’s evaluation of managerial efforts. Plus, they offer valuable advice for crypto projects seeking regulatory clarity and reflect on their own journeys in the crypto world.
AI Snips
Chapters
Transcript
Episode notes
Five-Month Regulatory Dialogue
- DoubleZero began engaging the SEC in April after Conor suggested they speak with regulators.
- The team spent about five months working with staff before the SEC prepared the no-action letter.
Translate Tech Into Lawyer Language
- Translating technical materials into lawyer-friendly primers was the first step.
- That framing helped the Division of Corporation Finance quickly grasp D‑PIN nuances and ask focused legal questions.
Timing Matters: Ask Prospectively
- The token wasn't live when they sought relief, which was essential.
- No‑action letters must be prospective, so forward-looking facts mattered greatly.