US SEC Digital Assets and Crypto Regulatory Framework
Evidence request list. 8 controls, 8 carrying auditor artefact guidance. Generated from the compliance knowledge graph on 12 September 2026. Published by The Art of Service.
AML
Per SEC + FinCEN + OFAC: Sanctions and AML Coordination + Whistleblower and Internal Reporting Channels.
- SEC Crypto evidence for USSECCRYPTO-4
- classification + custody partial
Classification
Per SEC + Howey Test: classify crypto assets as securities. Requirements include (a) Reliance on Efforts of Others Assessment + (b) Investment of Money + (c) Common Enterprise + (d) Expectation of Profits + (e) maintain documentation.
- SEC Crypto evidence for USSECCRYPTO-1
- classification + custody partial
Conduct
Per SEC: custody + broker-dealer registration + market conduct + Marketing and Solicitation Rules.
- SEC Crypto evidence for USSECCRYPTO-3
- classification + custody partial
Enforcement
Per SEC: enforcement + cooperation + voluntary disclosure + crypto-specific actions.
- SEC Crypto evidence for USSECCRYPTO-5
- classification + custody partial
Registration
Per SEC: registration + exemptions (Reg A + D + S) + disclosures + Form S-1 + 10-K + 10-Q.
- SEC Crypto evidence for USSECCRYPTO-2
- classification + custody partial
Securities Classification of Digital Assets
Investment contract analysis for digital assets. Investment of money. Common enterprise. Expectation of profits. Derived from efforts of others. Economic reality analysis. Sufficiently decentralised test.
- Howey Test analysis memoranda for each digital asset offering
- Securities registration filings or exemption documentation
- Custody arrangement documentation with qualified custodians
- Disclosure documents omit material technology and operational risks
- Surveillance procedures inadequate for emerging market manipulation patterns
- Registration exemption reliance not periodically re-validated
- Howey Test analysis lacks documented application to specific facts
- Custody arrangements not aligned with qualified custodian requirements
Exchange registration for digital asset securities. Broker-dealer registration. Transfer agent registration. Investment adviser registration. Form S-1 for token offerings. Regulation D exemptions. Regulation A+ offerings.
- Disclosure documents addressing material risks of digital assets
- Anti-fraud policy and surveillance procedure documentation
- Legal opinions on asset classification under federal securities laws
- Howey Test analysis memoranda for each digital asset offering
- Registration exemption reliance not periodically re-validated
- Howey Test analysis lacks documented application to specific facts
- Custody arrangements not aligned with qualified custodian requirements
- Disclosure documents omit material technology and operational risks
- Surveillance procedures inadequate for emerging market manipulation patterns
Bitcoin spot ETF approvals (January 2024). Ethereum spot ETF approvals. ETF custody requirements. NAV calculation. Creation/redemption mechanism. Surveillance-sharing agreements. Authorised participant framework.
- Securities registration filings or exemption documentation
- Custody arrangement documentation with qualified custodians
- Disclosure documents addressing material risks of digital assets
- Anti-fraud policy and surveillance procedure documentation
- Legal opinions on asset classification under federal securities laws
- Surveillance procedures inadequate for emerging market manipulation patterns
- Registration exemption reliance not periodically re-validated
- Howey Test analysis lacks documented application to specific facts
- Custody arrangements not aligned with qualified custodian requirements
Assembled from the framework’s own control set, so this list is regenerated rather than written and stays current as the graph does.