Author

Samuel Kramer

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Blockchain technology was born in the midst of the financial crisis and proposed as a means of reliably transferring a store of value without using a bank or other financial intermediary. Bitcoin was the first such blockchain token, and multiple cryptocurrencies have followed. But blockchain use cases extend far beyond the financial world, and some of the more creative uses of blockchain technology have emerged in the supply chain. The numerous benefits of blockchain to…

A new interpretation of the Commodities and Futures Trading Commission (the CFTC) removes some uncertainty from a key exemption for virtual currencies. On March 23, 2020, the CFTC approved its final interpretive guidance on the meaning of the term “actual delivery”. In order for retail commodity transactions involving digital assets to be exempt from CFTC regulation under the Commodity Exchange Act (CEA), the transaction must result in actual delivery within 28 days, or such other…