Laurie Rosini, an attorney in the Technology Transactions & Privacy practice, focuses her practice on electronic financial services, blockchain technology and digital currencies, and privacy and data security. Laurie has experience reviewing clients’ products and services to ensure sound privacy policies, data security practices and transaction processing. Laurie also counsels clients regarding the regulatory compliance issues facing electronic financial services businesses and virtual currency firms.

On December 15, 2017, the U.S. Commodity Futures Trading Commission (the “CFTC“) issued a proposed interpretation of the term “actual delivery” as used in the provision of the Commodity Exchange Act (the “CEA“) that grants the CFTC explicit authority to oversee the marketplace for “retail commodity transactions”.  This is the first blog posting in a multi-part series that will explore the regulation of retail commodity transactions and the CFTC’s recent proposed interpretation (the “Proposed Interpretation“), the issuance of which we believe has represents a potentially significant milestone in the regulation of virtual currency transactions.  We begin our series with a brief look at the history and background of the regulation of retail commodity transactions.
Continue Reading Retail Commodity Transactions Involving Virtual Currencies: An Overview of the CFTC’s Proposed Interpretation (Part 1)