Document Type


Publication Date


Publication Citation

75 Business Lawyer 1695 (2019-2020)


Federal and state developments affecting e-payments and financial services between June 1, 2018, and May 31, 2019, as in recent years, exceeded the space allowed for this survey. We have chosen to feature continuing regulatory efforts, including new guidance and innovations in cryptocurrencies as payments methods or as tradable "digital assets," and enforcement actions related to cryptocurrencies and to providers and users of cryptocurrencies. This survey also identifies guidance and enforcement actions that relate to providers of other types of financial products or services. Part II evaluates developments relating to cryptocurrencies, both as payment products and otherwise as "digital assets" or "tokens" offered to the public that may meet requirements for "investment contracts" that the United States regulates as "securities." Part III covers developments for other payment and financial products. Part IV offers conclusions and predictions of "hot topics" for the coming survey year.