US Federal Regulatory Landscape
of Blockchain Technology

Atlanta Federal Reserve

August 2014:
White Paper: “Making Change What Bitcoin Could Mean to the Payments Industry”:
https://www.frbatlanta.org/-/media/documents/regional-economy/econsouth/14q2-making- change-what-bitcoin-could-mean.pdf

October 2015; Revised February 2016:
Retail Payment Risk Forum Working Paper: “Banking Bitcoin-Related Businesses: A Primer for Managing BSA/AML Risks”, by Douglas King:
https://www.frbatlanta.org/-/media/documents/rprf/rprf_pubs/2016/banking-bitcoin-related- businesses.pdf

Commodity Futures Trading Commission

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June 2, 2016:
Press Release: “CFTC Orders Bitcoin Exchange Bitfinex to Pay $75,000 for Offering Illegal Off- Exchange Financed Retail Commodity Transactions and Failing to Register as a Futures Commission Merchant”:
http://www.cftc.gov/PressRoom/PressReleases/pr7380-16

May 17, 2017:
Press Release: “CFTC Launches LabCFTC as Major FinTech Initiative”:
http://www.cftc.gov/PressRoom/PressReleases/pr7558-17

July 24, 2017;
Press Release: “CFTC Grants DCO Registration to LedgerX LLC”:
http://www.cftc.gov/PressRoom/PressReleases/pr7592-17

Conference of State Bank Supervisors

April 26, 2017:
Press Release: “CSBS Files Complaint Against Comptroller of the Currency”:
https://www.csbs.org/news/press-releases/pr2017/Pages/042617.aspx
Complaint:
https://bankcsbs.files.wordpress.com/2017/04/csbs-occ-complaint-final.pdf

May 12, 2017:
Press Release: “CSBS Statement on New York Department of Financial Services Lawsuit Against OCC”:
https://www.csbs.org/news/press-releases/pr2017/Pages/051217.aspx

Congressional Research Service

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July 2014:
Bitcoin: Questions, Answers, and Analysis of Legal Issues
https://fas.org/sgp/crs/misc/R43339.pdf

Federal Reserve

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December 2016:
Working Paper: “Distributed Ledger Technology in Payments, Clearing, and Settlement”: https://www.federalreserve.gov/econresdata/feds/2016/files/2016095pap.pdf

March 3, 2017:
Speech: “Innovation, Technology, and the Payments System,” given at the Yale Law School Center on March 3, 2017, by Governor Jerome H. Powell:
https://www.federalreserve.gov/newsevents/speech/powell20170303a.htm

October 7, 2016:
Speech: “Distributed Ledger Technology: Implications for Payments, Clearing, and Settlement,” given at the Institute of International Finance Annual Meeting on Ocober 7, 2016, by Governor Lael Brainard:
https://www.federalreserve.gov/newsevents/speech/brainard20161007a.htm

Federal Trade Commission

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June 22, 2015:
Consumer Information Blog: “Before paying with bitcoins…”:
https://www.consumer.ftc.gov/blog/paying-bitcoins

Financial Crimes Enforcement Network (Department of the Treasury)

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June 12, 2015:
Report: “National Money Laundering Risk Assessment (2015)” (pg. 57 speaks about virtual currencies):
https://www.treasury.gov/press-center/press-releases/Pages/jl0072.aspx

Financial Industry Regulatory Authority

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March 31, 2017:
Chamber of Digital Commerce Comments Letter: “Comments on FINRA’s Report on Distributed Ledger Technology: Implications of Blockchain for the Securities Industry”:
http://www.finra.org/sites/default/files/Blockchain-SFIG-Comment.pdf

January 2017:
Official Report: “Report on Distributed Ledger Technology: Implications of Blockchain for the Securities Industry”:
http://www.finra.org/sites/default/files/FINRA_Blockchain_Report.pdf

Financial Stability Oversight Council
Government Accountability Office

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April 2017:
Report: “Financial Technology – Information on Subsectors and Regulatory Oversight”:
https://www.gao.gov/assets/690/684187.pdf

Internal Revenue Service

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November 30, 2016:
Release: “Court Authorizes Service of John Doe Summons Seeking the Identities of U.S. Taxpayers Who Have Used Virtual Currency”:
https://www.justice.gov/opa/pr/court-authorizes- service-john-doe-summons-seeking-identities-us-taxpayers-who-have-used

National Institute of Standards and Technology

June 22, 2017:
Guidelines: “NIST Digital Identity Guidelines 800-63-3”:
https://pages.nist.gov/800-63-3/

New York Department of Financial Services

May 12, 2017:
Press Release: “Statement by Superintendent Maria T. Vullo On The Department Of Financial Services Lawsuit Challenging The OCC’s Unauthorized Decision to Grant “Special Purpose” National Bank Charters To Undefined “Fintech” Companies”:
http://www.dfs.ny.gov/about/press/pr1705122.htm
Complaint:
http://www.dfs.ny.gov/about/ea/ea170512.pdf

Office of the Comptroller of the Currency

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December 2016:
Report: “Exploring Special Purpose National Bank Charters for Fintech Companies”:
https://www.occ.treas.gov/topics/responsible-innovation/comments/special-purpose-national- bank-charters-for-fintech.pdf

December 2, 2016
Remarks: “Special Purpose National Bank Charters for Fintech Companies,” given at Georgetown University Law Center on December 2, 2016, by Thomas J. Curry:
https://www.occ.gov/news-issuances/speeches/2016/pub-speech-2016-152.pdf

December 20, 2016:
Federal Register: “Relationships for Uninsured National Banks”:
https://www.gpo.gov/fdsys/pkg/FR-2016-12-20/pdf/2016-30666.pdf

March 15, 2017:
Release: “OCC Issues Draft Licensing Manual Supplement for Evaluating Charter Applications From Financial Technology Companies, Will Accept Comments Through April 14”:
https://www.occ.gov/news-issuances/news-releases/2017/nr-occ-2017-31.html

July 19, 2017:
Speech: Remarks by Keith A. Noreika, Acting Comptroller of the Currency, given at Exchequer Club on July 19, 2017:
https://www.occ.gov/news-issuances/speeches/2017/pub-speech-2017- 82.pdf

Securities and Exchange Commission

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March 10, 2017:
Release: Order Disapproving a Proposed Rule Change: “Self-Regulatory Organizations; Bats BZX Exchange, Inc.; Order Disapproving a Proposed Rule Change, as Modified by Amendments No. 1 and 2, to BZX Rule 14.11(e)(4), Commodity-Based Trust Shares, to List and Trade Shares Issued by the Winklevoss Bitcoin Trust”:
https://www.sec.gov/rules/sro/batsbzx/2017/34-80206.pdf

March 28, 2017:
Release: Self-Regulatory Organizations; NYSE Arca, Inc.; “Order Disapproving a Proposed Rule Change, as Modified by Amendment No. 1, Relating to the Listing and Trading of Shares of the SolidX Bitcoin Trust under NYSE Arca Equities Rule 8.201”: https://www.sec.gov/rules/sro/nysearca/2017/34-80319.pdf

June 30, 2017:
Litigation Release: “Securities and Exchange Commission v. Renwick Haddow, et al., Civil Action No. 17-cv-4950 (S.D.N.Y., filed June 30, 2017) – SEC Files Fraud Charges in Bitcoin and Office Space Investment Schemes”: https://www.sec.gov/litigation/litreleases/2017/lr23870.htm

SEC Enforcement Cases

July 11, 2016:
Administrative Order: “In the Matter of Bitcoin Investment Trust and SecondMarket, Inc.”:
https://www.sec.gov/litigation/admin/2016/34-78282.pdf

Administrative Proceeding: “SecondMarket, Inc. and Bitcoin Investment Trust (BIT) Settle Charges Relating to Unlawful Redemptions of BIT Shares during a Continuous Distribution”:
https://www.sec.gov/litigation/admin/2016/34-78282-s.pdf

February 3, 2017:
Release: “Self-Regulatory Organizations; NYSE Arca, Inc.; Notice of Filing of Proposed Rule Change Relating to the Listing and Trading Shares of the Bitcoin Investment Trust under NYSE Arca Equities Rule 8.201”:
https://www.sec.gov/rules/sro/nysearca/2017/34-79955.pdf

April 11, 2017:
Administrative Order: “In the Matter of Sunshine Capital, Inc. and Jimmy Wayne Anderson”:
https://www.sec.gov/litigation/opinions/2017/34-80874.pdf

Release [Regarding Sunshine Capital, Inc.]: “Securities Exchange Act of 1934, Release No. 80435”:
https://www.sec.gov/litigation/suspensions/2017/34-80435.pdf

U.S. Attorney’s Office Lawsuit Against Renwick Haddow

June 30, 2017:
Press Release: “Charges Unsealed Against British Citizen For Defrauding Investors Of More Than $36 Million”
https://www.justice.gov/usao-sdny/pr/charges-unsealed-against-british-citizen-defrauding-investors-more-36-million

Uniform Law Commission
United Nations
World Bank

September 22, 2016:
Report: “The Inclusion of Blockchain”:
http://pubdocs.worldbank.org/en/383631476811912188/Session-5C-Michael-Casey-Global- Symposium-Slides.pdf

June 16, 2016:
World Bank Blog: “Blockchain technology: Redefining trust for a global, digital economy”:
http://blogs.worldbank.org/ic4d/blockchain-technology-redefining-trust-global-digital-economy

May 2017:
Report: “Can Blockchain Technology Address De-Risking in Emerging Markets?”:
https://www.ifc.org/wps/wcm/connect/e61e2d89-7e8e-4b55-9b22-95769263b3e9/EMCompass+Note+38+Derisking+and+Blockchain+5-24+FINAL.pdf?MOD=AJPERES

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