Despite its cooperative efforts, Coinbase faces a $50 million penalty and a commitment to spending an additional $50 million to improve its compliance framework under the recent Consent Order. 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 “The Great Resignation: Cyber Risks in the Crypto Sector
” (Oct. 26, 2022).