Dave Kappos and Evan Norris Author Article for CoinDesk

Cravath partners David J. Kappos and Evan Norris and associate Daniel M. Barabander authored an article entitled “More than Just the Ooki DAO: Lessons for Web3 Companies About Control After bZx,” which was published by CoinDesk on October 31, 2022. The article examines the recent enforcement actions taken by the Commodity Futures Trading Commission (CFTC) against bZeroX LLC, its co‑founders and the associated “decentralized autonomous organization,” Ooki DAO. The article analyzes how regulators at the CFTC examined both technical and business control in order to draw the line between identifiable persons and autonomously run protocols and hold operators accountable.

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