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McDermott Will & Emery

CFTC Staff Letter 25-14: What Is a “U.S. Person”?

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On May 21, 2025, the Commodity Futures Trading Commission’s (CFTC) Market Participants Division and Division of Market Oversight jointly issued Staff Letter 25-14 in response to a request from SCB Limited, a Bahamas-based...more

Conyers

Virtual Asset Service Providers – CIMA Regulatory Policy

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The Cayman Islands Monetary Authority (“CIMA”) has issued a regulatory policy (the “Policy”) outlining the criteria for approving Registration or Licensing of Virtual Asset Service Providers (“VASPs”). The Policy applies to...more

Vinson & Elkins LLP

Failure to Register: SEC Shows No Signs of Letting Up on Crypto

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Cryptocurrency had a rocky 2022. Bitcoin, often touted as a hedge against inflation, lost nearly 65 percent of its value. FTX, one of the most popular and well-known platforms for trading crypto, declared bankruptcy. Its...more

Oberheiden P.C.

Security Token Offerings (STOs) For NFTs? – 5 Things You Should Know Before You Take the Plunge

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STOs and NFTs - STOs stands for “security token offerings.” They involve an offering of digitalized securities such as stocks, bonds, or other token and coin projects. The difference between an IPO and an STO is that STOs...more

Proskauer - Blockchain and the Law

CFTC Issues Cease and Desist Order to Binary Options Operator Using Smart Contracts

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On January 3, 2022, the Commodity Futures Trading Commission (the “CFTC”) entered an order charging Blockratize, Inc. (d/b/a Polymarket.com) (“Polymarket”) with offering off-exchange binary options contracts and failing to...more

White & Case LLP

CFTC Jurisdiction Over Cryptocurrency – Implications for Industry Participants

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On October 10, 2019, CFTC Chairman Heath Tarbert commented on Ether’s status as a commodity: “We’ve been very clear on bitcoin: bitcoin is a commodity under the Commodity Exchange Act. We haven’t said anything about Ether –...more

Wilson Sonsini Goodrich & Rosati

Virtual Currency Guidance + Enforcement Actions = AML Regulators Are Watching

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A few days before thousands of blockchain industry participants poured into New York for “Blockchain Week,” the Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) issued guidance on virtual currencies...more

Perkins Coie

Blockchain Week in Review - February 2019 #4

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U.S. Developments - Regulatory Updates - SEC Settles Enforcement Action with Gladius Network - On February 20, 2019, the U.S. Securities and Exchange Commission (“SEC”) announced the settlement of charges against...more

Perkins Coie

The SEC and Digital Assets—A Busy Year End

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The end of the year has been a very busy time for the SEC in the digital asset space. From speeches to the issuance of joint statements to enforcement actions, there are many things to highlight, discuss and consider. This...more

Troutman Pepper Locke

Staking its Claim: SEC Provides Comprehensive Guide for Blockchain, Digital Asset Securities

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Yesterday at the Consensus: Invest Conference in New York City, Jay Clayton, Chairman of the U.S. Securities and Exchange Commission (the “Commission”), strongly reaffirmed the guidance put forth by his agency in the last...more

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