Despite Coinbase's efforts to cooperate with regulators, a recent NYDFS consent order requires it to pay a $50 million penalty and spend another $50 million to improve its compliance framework. Also, on February 7, 2023, the DOJ announced that a former Coinbase product manager pled guilty to two counts of conspiracy to commit wire fraud, each carrying a maximum sentence of 20 years in prison, becoming the first insider to admit guilt in an insider trading case involving the cryptocurrency markets. With regulatory oversight of crypto still in its nascency while the crypto industry implodes, did Coinbase, the biggest U.S. cryptocurrency exchange, get caught in this crossfire as a warning to other crypto players? Or did it knowingly rest on its laurels, hoping that check-the-box activities would suffice? See “Protecting Against Crypto Theft” (Aug. 10, 2022).