Page 27 - 期货和衍生品行业监管动态（2024年9月刊）

期货和衍生品行业监管动态

via a decentralized digital asset trading protocol. The order requires Uniswap Labs to

pay a $175,000 civil monetary penalty and to cease and desist from violating the

Commodity Exchange Act (CEA), as charged.

“Today’s action demonstrates once again the Division of Enforcement will

vigorously enforce the CEA as digital asset platforms and DeFi ecosystems evolve”

said Director of Enforcement Ian McGinley. “DeFi operators must be vigilant to

ensure that transactions comply with the law.”

Case Background

Uniswap Labs contributed to the development, and deployed versions, of a

blockchain-based digital asset protocol that offered to non-Eligible Contract

Participants and institutional users in the United States and abroad the ability to trade

digital assets through use of the Ethereum blockchain. The protocol allows users to

create and trade with liquidity pools, which consist of a matched pair of digital assets

that are valued against each other.

In order to facilitate access to the protocol, Uniswap Labs developed and

maintained a web interface that it made available to users. Through the interface,

users could trade in hundreds of liquidity pools on the protocol. Among the digital

assets traded on the protocol and through the interface were a limited number of

leveraged tokens, which provided users leveraged exposure to digital assets such as

Ether and Bitcoin. The order finds these leveraged tokens are leveraged or margined

commodity transactions that did not result in actual delivery within 28 days and

therefore can be offered to non-Eligible Contract Participants only on a board of trade

that has been designated or registered by the CFTC as a contract market, which

Uniswap Labs was not.

As stated in the order, the CFTC recognizes Uniswap Labs’ substantial

cooperation with the Division of Enforcement’s investigation of this matter in the

form of a reduced civil monetary penalty.

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