CFTC Virtual Currency Guidance:  CFTC Issues Guidance on What Constitutes the “Actual Delivery” of Virtual Currencies in the Context of Retail Commodity Transactions

Sullivan & Cromwell LLP - March 26, 2020
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On March 23, 2020, the Commodity Futures Trading Commission voted unanimously to approve publication of final interpretive guidance, following a 2017 proposal, on the definition of “actual delivery” in the context of a retail commodity transaction involving virtual currencies and entered into with a party that is not an “eligible contract participant,” as defined under the Commodity Exchange Act.