The Traveling Wilburys famously noted “In Jersey, anything's legal as long as you don't get caught.”[1] Apparently the New Jersey Bureau of Securities (“Bureau”) disagrees. The Bureau issued a Summary Cease and Desist Order to BlockFi Inc. (“BlockFi”) on July 20, 2021, ordering the company to stop offering interest-bearing cryptocurrency[2] accounts to new customers in New Jersey. According to the Order, BlockFi, through its affiliates, has been facilitating its cryptocurrency lending and proprietary trading operations through the sale of unregistered securities in violation of New Jersey’s securities laws. “Our rules are simple: if you
