Cosme LLC

A boutique law firm focusing on corporate and regulatory counseling for companies and investors in crypto, digital assets, and AI.

[Cosme LLC @CosmeLaw]

The @USOCC has published its final GENIUS Act rule.

It sets licensing, reserve, redemption, capital, and risk management standards for stablecoin issuers under the OCC’s jurisdiction, and it takes effect with the Act on January 18, 2027.

On that same date, the Act begins to limit which stablecoins exchanges, wallets, payment companies, and other intermediaries may offer to people in the United States.

In a new client alert, @Orlando_btc summarizes what the rule means for issuers and their vendors, including the OCC’s narrow reading of the yield ban and the obligations issuers must pass to vendors by contract, and what the Act means for companies that move, trade, or reward stablecoins.

The alert closes with six steps to take now.

https://t.co/MVph7B42fy

[zeroxyz.btc 🏹🟧🇺🇸 @xyzerobtc]

@Orlando_btc @CosmeLaw Been a happy customer of Cosme LLC @CosmeLaw for years now
Keep doing great work sir

[Cosme LLC @CosmeLaw]

When an AI agent runs a crypto vault, who is the manager?

AI agents are beginning to run crypto vaults—choosing strategies, moving funds across protocols, and signing transactions without a human approving each trade. Many builders assume that taking the human out makes the product look more like neutral software. Instead, an agent that decides where and when to allocate can make it look more like a managed product.

In a new article, @Orlando_btc examines eight design decisions every agent vault builder makes, from key control to disclosure, and the legal consequences of each under securities, commodities, and money transmission law, with structuring ideas for each. The article closes with ten questions to answer before launch.

https://t.co/lZukmOYl0U

[Orlando Cosme @Orlando_btc]

@AnthropicAI filed its S-1 today, and most of the attention is on revenue.

Deservedly so. It went from $1.2B in the first half of 2025 to $16.3B in the first half of 2026.

Others are focusing on the risk factors, which include models taking harmful actions no user directed and export restrictions that took two of its models offline for about three weeks. Also fair.

But what surprised me, and what I think is underappreciated, is the company's governance structure.

Anthropic will have five classes of common stock:

Class A: public. One vote per share.
Class N: strategic partners. Same economics, no vote.
Class T: the Long-Term Benefit Trust. No economics, but it elects a majority of the board.
Class F: one share, held by an LLC of the seven co-founders. 50.1% of the vote on everything else.
Class E: employees. No economics, but a vote on changes to the trust and on one contested board seat.

The trust is a Delaware noncharitable purpose trust. It has no beneficiaries, and it holds the stock that picks the board majority.

If you're experienced with crypto corporate structures, you've probably seen something similar with a Cayman or Swiss foundation for a protocol. It's an attempt to put technology under the control of a public mission instead of self-interested individuals. I can't think of another public company with a structure like this at the top.

The founder share is built to wind down once fewer than three of the seven are left. The trust, on the other hand, has no comparable sunset.

Anthropic is also a public benefit corporation, so its board has to balance shareholder returns against its mission. Under DGCL § 367, shareholders holding as little as $2M of stock can sue to enforce that duty. The filing concedes there's little case law on what this balance requires.

The real test is the first time the trust and the public shareholders want different things. It shouldn't take long.

[Orlando Cosme @Orlando_btc]

The @SECGov’s proposed Regulation Crypto Assets is a major step forward for crypto.

I applaud the Commission for using its rulemaking authority to write rules that fit what crypto technology enables, and for moving away from “regulation by enforcement.”

But my clients are exactly the companies that would issue tokens under Reg CA, and as drafted, I don’t think many of them will use it. Too many practical issues would steer a token issuer away.

So we at @CosmeLaw submitted a comment letter proposing targeted fixes that reflect how token projects are built, financed, and launched today, so that Reg CA becomes an exemption token issuers actually rely on.

Full letter in the link below.

[Cosme LLC @CosmeLaw]

Last week, Cosme LLC submitted a comment letter to @SECGov on proposed Regulation Crypto Assets (Reg CA), written by our founder @Orlando_btc.

Reg CA would give U.S. crypto projects a clear legal path to launch a token. We applaud the SEC and its Crypto Task Force for building these rules with the industry.

As drafted, though, many startups may not use it:
– Pre-launch posts may be offers outside any exemption
– Venture financings may not be covered investment contracts
– Testnet rewards may use up the $5M limit
– Launch platforms may need to register as broker-dealers

Our letter proposes a targeted fix for each within Reg CA’s existing framework.

https://t.co/YjEn5B3u6j

[Orlando Cosme @Orlando_btc]

OC Advisory is now Cosme LLC (@CosmeLaw).

Three and a half years ago, I started the firm as something to do while I figured out my next step after my failed startup. Turns out, that was the next step.

It has since grown from a solo practice into a small team of attorneys serving some of the leading companies and investors in crypto and digital assets.

We've worked on everything from leading venture investments and nine-figure M&A to designing multi-billion-dollar token networks and tokenization frameworks for strategic energy commodities—it's been a ride.

To every client—whether you were a founder with no entity yet and a few angel checks lined up, or the development company behind one of crypto's most prominent protocols—thank you, from the bottom of my heart, for trusting us with your most important matters.

More to come soon.