A recent federal district court ruling in a criminal anti-money laundering case suggests that the transmission of virtual currency on behalf of another person requires a state money transmission license—even if the state’s...more
Developments in virtual currency regulation have been top-of-mind with recently announced initiatives from the New York Department of Financial Services. Companies engaging in virtual currency activity should also, however,...more
On March 24, 2020, the Commodity Futures Trading Commission (“CFTC”) issued its final interpretive guidance (the “Interpretation”) concerning the meaning of “actual delivery” in the context of retail commodity transactions...more
On May 9, 2019, the Financial Crimes Enforcement Network (“FinCEN”) issued a guidance, Application of FinCEN’s Regulations to Certain Business Models Involving Convertible Virtual Currencies (CVC) (“Guidance”), together with...more
Until November 8, 2018, the enforcement actions of the U.S. Securities and Exchange Commission (SEC) in the digital token (aka cryptocurrency) space have primarily focused on the primary issuances of tokens. However, on...more