Elena advises on when a digital asset activity is a securities offering, a dealer business, an investment-adviser activity, or none of those. She previously served in the SEC’s Division of Corporation Finance, working on novel-product interpretation and registered offerings.
Issuers, exchanges, and funds use her for classification memos that operations teams can actually follow, for comment-letter and rulemaking strategy, and for the unglamorous work of building a listing or custody committee that leaves a record.
She is a frequent speaker at practitioner roundtables on Regulation Crypto Assets and custody under the Advisers Act and the Investment Company Act. She is admitted in New York and the District of Columbia.
Representative work
- Structuring counsel on a registered and exempt digital-securities program for an asset manager.
- Lead regulatory counsel for an exchange preparing a response to proposed CFTC crypto-trading rules.
- Advice to a bank subsidiary on a limited custody pilot and the state-trust alternative.