Christopher L. Boone

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Last week the SEC offered its clearest guidance yet on when blockchain tokens and other digital assets would be classified as “securities” under U.S. securities law and subject to SEC regulation. Specifically, the SEC’s Strategic Hub for Innovation and Financial Technology (FinHub) issued its first-ever “Framework for ‘Investment Contract’ Analysis of Digital Assets.”…
CU Ledger, a consortium of U.S. credit unions, announced on Monday, March 11, that it will work with IBM to develop blockchain solutions to improve services such as identity authentication and know-your-customer (KYC) compliance. CU Ledger also indicated it is looking to blockchain to improve payments and lending. Marie Wieck, General Manager, IBM Blockchain explained that through their collaboration, “credit unions will be able to cooperate and receive shared value from quickly exchanging sensitive data…
Companies involved in global supply chain services are becoming increasingly interested in blockchain technology and how the use of this technology can enhance efficiency and security within the supply chain. Blockchain-based applications have enormous potential to transform transportation and logistics operations in the United States and worldwide. Last month at Transparency 18 in Atlanta, approximately 40 companies performed demonstrations for supply chain stakeholders from around the world exhibiting how software using blockchain and other disruptive…
The Office of Foreign Assets Control (“OFAC”), responsible for enforcing U.S. economic sanctions, has taken its first steps to tackle the exploding use of digital currencies. On March 19, 2018, OFAC released a digital currency-related FAQ indicating that OFAC may include digital currency addresses on its Specially Designated Nationals (“SDN”) list of blocked persons, companies and entities. In its guidance, OFAC defines digital currency broadly to include “sovereign cryptocurrency, virtual currency (non-fiat), and a digital…
The Subcommittee on Capital Markets, Securities, and Investment held a hearing, “Examining Cryptocurrencies and ICO Markets,” this past Wednesday, March 14, 2018. The stated goal of the hearing was to achieve greater regulatory clarity in the cryptocurrency and ICO markets, especially as these markets continue to grow and attract attention from investors and enterprises in pursuit of capital. Members of the subcommittee indicated that achieving this regulatory clarity would be critical to ensuring that…
The Wall Street Journal reported on Wednesday, February 28, 2017, that the Securities and Exchange Commission (SEC) has issued “scores of subpoenas and information requests to technology companies and advisers” in a sweeping probe of the Initial Coin offering (ICO) and Token Sale industry. By way of background, ICOs or “Token Sales” typically involve the offer and sale of digital assets utilizing distributed ledger or blockchain technology. According to the report, the SEC is seeking…