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Troutman Pepper

Crackdown on DeFi? An Examination of the CFTC's Enforcement Action Against Uniswap — The Crypto Exchange

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In the latest episode of The Crypto Exchange, host Ethan Ostroff is joined by Addison Morgan to discuss the recent CFTC enforcement action against Uniswap. The CFTC alleged that Uniswap violated the Commodity Exchange Act...more

BakerHostetler

Weekly Blockchain Blog - September 2024 #4

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Payments Firms Launch Crypto Products, New Crypto Adoption Data Published - According to a recent press release, a well-known U.S. payments and financial technology company announced that it will allow its United States...more

Lowenstein Sandler LLP

DeFi Takes Another Hit: CFTC Settles With Uniswap Labs Over Leveraged Tokens

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On September 4, the Commodity Futures Trading Commission (CFTC) issued a settlement order (the Order) against Universal Navigation Inc. d/b/a Uniswap Labs (Uniswap).1 The Order asserted that Uniswap, through its front-end...more

BakerHostetler

Weekly Blockchain Blog - July 2024 #3

BakerHostetler on

Stablecoin Demand Increases with Initiatives Announced in Germany, Hong Kong - Recent reports highlight an increasing demand for stablecoins. According to one report, the market cap of the PYUSD stablecoin recently...more

Polsinelli

Blockchain+ Bi-Weekly - March 2024 #2

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It was a busy two weeks in Web3 law, as Binance lost in an appeal that could have wide-ranging jurisdictional implications outside of just digital assets. Coinbase also went on the offensive against the SEC in appealing the...more

Goodwin

The CFTC’s DeFi Trifecta: Lessons and Implications for DeFi Participants Inside and Outside the US

Goodwin on

On September 7, 2023, the Commodity Futures Trading Commission (CFTC) announced the settlement of three separate enforcement actions in the decentralized finance (DeFi) space: namely, concerning the Opyn protocol and its...more

Proskauer - Blockchain and the Law

From Code to Consequence: CFTC Obtains Default Judgment Against Ooki DAO for Commodity Exchange Act Violations

Unlike traditional corporate entities with a typical hierarchical structure, a decentralized autonomous organization (“DAO”) – a management structure that uses blockchain technology – functions as a leaderless entity. Without...more

Manatt, Phelps & Phillips, LLP

Blockchain Update: Lummis-Gillibrand Crypto Regulation Bill Reintroduced Following Tumultuous Year

Sens. Cynthia Lummis (R. Wyo.) and Kristen Gillibrand (D. N.Y.) have reintroduced their landmark bipartisan crypto bill known as the Lummis-Gillibrand Responsible Financial Innovation Act (“Lummis-Gillibrand Act” or “LG...more

Latham & Watkins LLP

What’s Next for DAOs in the Wake of the Ooki Decision?

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The viability of DAO structures draws attention after a judge declares that a decentralized autonomous organization is a “person” under the law. On June 8, 2023, the US District Court for the Northern District of...more

ArentFox Schiff

Service of Process in the Digital Age: Twitter, Blockchain, and Chatbox Valid Methods or Modern Nail & Mail?

ArentFox Schiff on

Courts across the United States are grappling with the application of traditional legal principles to "Web3” technologies and tools, such as blockchain, NFTs, and decentralized autonomous organizations (DAOs). Among other...more

Morgan Lewis - All Things FinReg

Court OKs CFTC’s Service of Process Through Online Forum, Chat Box in Ooki DAO Action

The US District Court for the Northern District of California ruled on December 20, 2022, that the Commodity Futures Trading Commission (CFTC) properly served the defendant, Ooki DAO, by posting summons documents in Ooki...more

Skadden, Arps, Slate, Meagher & Flom LLP

CFTC Settles Claims Against Founders of a Decentralized Protocol and Sues Its Successor DAO and Its Members, Pressing a Novel...

On September 22, 2022, the Commodity Futures Trading Commission (CFTC or Commission) (1) issued an order settling charges against protocol creator bZeroX, LLC and its founders, and (2) filed a federal civil enforcement action...more

Cadwalader, Wickersham & Taft LLP

DAOs in CFTC’s Enforcement Crosshairs

On September 22, the Commodity Futures Trading Commission (“CFTC”) asserted its jurisdiction over a decentralized autonomous organization (“DAO”) and its founders, signaling for the industry that even an unincorporated...more

Katten Muchin Rosenman LLP

Holders of DAO Governance Tokens Beware: According to the CFTC, Voting May Be Hazardous to Your Well-Being

Natural persons and legal entities are potentially jointly and severally liable for all of a decentralized autonomous organization's (DAO) violations of the Commodity Exchange Act (CEA) and Commodity Futures Trading...more

Paul Hastings LLP

VOTER BEWARE! Personal Liability for DAO Token Holders for Voting?

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New CFTC Action has Significant Implications for DAO Participation and Structures- Decentralized Autonomous Organizations (“DAOs”) provide a new way for individuals across the globe to use blockchain technology to pool...more

Katten Muchin Rosenman LLP

Exercise of Governance Tokens Could Result in Personal Liability for Illegal Activities of DeFi Protocol

Two natural persons who voted governance tokens issued by a decentralized finance (DeFi) protocol were charged with being “personally liable” for alleged violations of the Commodity Exchange Act (CEA) and regulations of the...more

Greenberg Glusker LLP

Vulnerability of Customers’ Crypto in Bankruptcy; Is Help on the Way?

Greenberg Glusker LLP on

The major cryptocurrencies have experienced significant declines in 2022; with the crypto market shedding $2 trillion of its peak $3 trillion market capitalization in November 2021. Amid this “crypto winter,” Terra Luna and...more

Skadden, Arps, Slate, Meagher & Flom LLP

Senate Bill Would Create Comprehensive Regulatory Structure for Cryptocurrencies and Other Digital Assets

In recent years, innovation in the blockchain or “Web3” space has been impacted by uncertainty on the regulatory front. Undoubtedly, the greatest area of uncertainty has involved the Securities Exchange Commission (SEC) and...more

Proskauer - Blockchain and the Law

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

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

Perkins Coie

Virtual Currency Legal Report: Week of January 7, 2022

Perkins Coie on

U.S. Congress to Hold Oversight Hearing on the Mining of Cryptocurrency - NY DFS to Hire New Deputy Superintendent - Recent Federal Regulator Announcements Signal Changes in Senior Leadership at the SEC, CFTC, and FDIC...more

Kohn, Kohn & Colapinto LLP

Whistleblowers Key to Combating Cryptocurrency Fraud

In September 2021, the market capitalization for digital assets, such as cryptocurrencies and NFTs, was valued at $2.14 trillion. The cryptocurrency market has attracted a variety of fraudulent activities in which the...more

King & Spalding

Decentralized Finance—Risks, Regulation, and the Road Ahead

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Even those who are most suspicious of the rise of cryptocurrency will likely admit that the underlying blockchain technology and its potential uses are exciting. One use of this technology, decentralized finance, or DeFi, is...more

Jones Day

DeFi Identified as Potential Focus for CFTC Enforcement Action

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CFTC Commissioner asserts that Decentralized Finance ("DeFi") likely violates the Commodity Exchange Act ("CEA") and that the regulator should respond accordingly. DeFi is an umbrella term encompassing a range of...more

White & Case LLP

Complementary: Bitcoin trading requires complementary to a financial activity authority under the Bank Holding Company Act

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There has been recent speculation that banks are about to enter the cryptocurrency markets. This makes a lot of commercial sense: There clearly is customer demand for banks to offer services similar to those they offer for...more

Perkins Coie

CFTC Finalizes Guidance on Digital Assets in the Context of Retail Commodity Transactions

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On March 24, 2020, the U.S. Commodity Futures Trading Commission (the Commission or the CFTC) finalized long-awaited interpretive guidance regarding what constitutes the “actual delivery” of a digital asset in the context of...more

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