The fast-growing decentralized finance (DeFi) system—the collection of finance applications built on blockchain technology—holds promise for a new financial architecture that can eliminate the need for traditional intermediaries (such as banks, brokers, and exchanges) and reduce rents (excess profits) in the financial sector. But it also generates formidable challenges for […]

Questions of which, if any, regulatory regimes apply to the variety of participants in the cryptocurrency market continue to dog the industry.  On February 28, 2022, whether a cryptocurrency futures trading platform constitutes a “futures commission merchant” (“FCM”) under the Commodity Exchange Act (“CEA”) subject to Bank Secrecy Act (“BSA”) […]

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