Part 2: CFTC Finalizes Guidance on Digital Assets in the Context of Retail Commodity Transactions

This is the second part of a three-part update series in order to provide the industry with a critical analysis of the U.S. Commodity Futures Trading Commission (CFTC) finalized long-awaited interpretive guidance regarding what constitutes the “actual delivery” of a digital asset in the context of a retail commodity transaction under the Commodity Exchange Act, published on March 24, 2020.

Part 1: Commentary on the Significance of the Guidance for the Industry can be viewed here.