Initial Coin Offerings (ICOs) have rapidly emerged as the hottest trend in FinTech financing, albeit one that is not without controversy. Put simply, an ICO is a method of fundraising somewhat akin to an initial public...more
10/31/2017
/ Anti-Money Laundering ,
Bitcoin ,
Broker-Dealer ,
CFTC ,
Commodity Exchange Act (CEA) ,
Cryptocurrency ,
Digital Currency ,
FinCEN ,
Initial Coin Offering (ICOs) ,
Investment Adviser ,
IRS ,
Securities Act of 1933 ,
Securities and Exchange Commission (SEC) ,
Securities Exchange Act ,
Virtual Currency
Introduction -
On July 12, 2013, the Commodity Futures Trading Commission (the “CFTC”) adopted interpretive guidance (the “Guidance”) that details the CFTC’s interpretation of the application of the Commodity Exchange...more
Recent changes to the commodity pool regulations under the Commodity Exchange Act (the “CEA”) may subject certain securitization transactions and their managers to regulation by the Commodity Futures Trading Commission (the...more