Mari Tomunen

@Austin_Federa I only say that because it is.

Today I learned our general council @MariTomunen thinks SantaCon is “wonderful” and “so much fun”

@JacobRobinsonJD @consensus2026 Yay! What about "new SEC" war stories?

Lawyers attending @consensus2026 in Miami next week: I've organized an invite-only green room of sorts poolside at the W Hotel in South Beach (8 min walk from the convention center). Plenty of drinks, snacks & "prior SEC" war stories. Pop-by anytime from 10 am to 3 pm on Wed, May 6. To get the RSVP link, just put a thumbs up below or send me a DM.

@doublezero DoubleZero Foundation was formed as a Cayman nonprofit in 2024. A lot has changed but many fundamentals remain the same. Looking forward to sharing our experience and hearing from my favorite @thatgerald and @libraticlex & Lucy at GAIM Ops on Monday.

Want to win? Here's Edge for you.

@ThaniaCh Incredible timing. Like they were listening. Next time I'll wish for a pony.

@MariTomunen It’s worth noting that you flagged this key question of when an asset is no longer subject to an investment contract on your panel at the DC summit today just hours before the interpretation was published. Quite timely!

Howey begins, and Howey ends. Highlights from the SEC and CFTC's joint guidance: 1. Tokens are not inherently securities. 2. Promises (roadmap/milestones) may create an investment contract (IC) around (or next to) the token. 3. Secondary market purchaser may still be inside the IC. Yikes. 4. IC ends when promises are met. 5. IC may start again (!) if new sales and promises/roadmaps are made. 6. Timing matters. The issuer’s post-sale promises do not convert the prior sale into an IC. (but see #5) Expecting to see "promises are now fulfilled" press releases from crypto projects in the coming weeks.

1/ Big news: @phantom has received first-of-its-kind no action relief from the @CFTC. We can now connect users to regulated derivatives markets and event contracts without registering as an introducing broker. cftc.gov/PressRoom/Pres…

@Austin_Federa @NYSE @doublezero Go get 'em.

Going on @NYSE TV this morning to talk about how @doublezero Edge is bringing some of the most powerful data tools in finance to onchain trading and crypto

@eden_ Ha, excellent adherence to the “all comms must be factually accurate” guidance.

The best GC in the game. @MariTomunen, a true force in helping to shape crypto law for our industry.

DoubleZero in @Forbes "Blockchain trading presents a challenge with no real equivalent in traditional finance. Imagine if the New York Stock Exchange jumped to a different location around the world every 1.6 seconds: now in New York, now London, now Singapore, now Hong Kong. That is exactly how a blockchain works, with the block leader rotating globally and constantly. Existing data distribution systems were never designed for this." forbes.com/sites/digital-…

@Austin_Federa @NeerajKA Where's my printer...I'll bring it!

@NeerajKA If we got a no action letter does @MariTomunen get a free ticket?

The Coin Center Annual Dinner will be on October 6 at Gotham Hall in NYC. This will sell out. Get your sponsorships in early. coincenter.org/dinner

@StaniKulechov That's way too busy

You know you’re busy when you don’t have the time for sauna

The SEC is more clearly defining what makes a blockchain token a security, writes adjunct prof. Mari Tomunen. news.bloomberglaw.com/legal-exchange…

A sculptor looks at a rock and sees a horse. A crypto lawyer looks at the SEC’s recent actions and sees a path: “Tokens” aren’t securities by default. But:  (1) The token must be actually functional (not just look, but also quack like a duck)  (2) Marketing goes full Taylor Swift: sell the show, not the flip "People often buy concert tickets intending to resell them at a higher price. Yet we don’t regulate concert tickets as securities. The reason is that Taylor Swift isn’t promising to increase ticket prices through her managerial efforts. She works hard to deliver an excellent show, but her marketing is all about the product rather than the ticket price." Thanks @BLaw for editing and publishing this piece. Massive shoutout to @_cathyyoon and Bianca Guimaraes-Chadwick for being amazing sounding boards.

We won’t rest until good-faith builders have clear, sensible rules of the road. More to do, but cheers to @SolanaInstitute for leading the policy effort.

It took T+14 to settle a trade in the early 19th century when a boat had to carry a paper certificate from London to New York. Now, NYSE says instant settlement. A game-changer for Wall Street.

Another SEC token no-action Letter - MegPrime - addresses token buybacks, market makers, among other things! It underscores the @doublezero blueprint: 1) the token is functional for a consumptive purpose, and (2) marketed accordingly (not as an investment). "The trading of MegPrime tokens in a secondary market, which will be facilitated by market makers, does not transform the tokens into securities." Full letter: sec.gov/files/corpfin/…

Thrilled and lucky to have @teemupai's experience and perspectives on the Board of DoubleZero Foundation. 🙌 🪑@doublezero

Our lawyer @MariTomunen said it's important I tweet DoubleZero® now that we have registered trademarks in the EU and US. Thank You For Your Attention To This Matter