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What the CFTC Interpretation of “Actual Delivery” Means for Crypto

The long-awaited guidance clarifies the application of the “actual delivery” exception to leveraged virtual currency transactions with retail purchasers. Earlier this year, the US Commodity Futures Trading Commission...more

Effective October 31, 2018: New NFA Virtual Currency Disclosure Requirements

The NFA will soon require CPO, CTA, FCM, and IB member firms to provide various disclosures warning investors of virtual currency spot and derivatives trading risks. New disclosure requirements warning customers,...more

Are Your Employees Trading Bitcoin? Addressing Cryptocurrencies in Compliance Policies

How should broker-dealers, investment advisers, and other registered firms in the US, UK, and Hong Kong address cryptocurrencies in their compliance programs? Originally published on bloombergbna.com on April 16,...more

CFTC Brings Significant Enforcement Action Against Online Cryptocurrency Exchange

The action reflects the CFTC’s expanded jurisdiction and provides further clarity on what constitutes “actual delivery” in cryptocurrency trading. On June 2, 2016, the US Commodity Futures Trading Commission (CFTC)...more

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