Update
SEC Staff Adds Crypto FAQs on Governance and Network Control
The U.S. Securities and Exchange Commission (SEC) staff has expanded its crypto asset FAQ with three new answers regarding governance and network control. The guidance clarifies who qualifies as a central party and distinguishes a functional network from a decentralized system. The Division of Corporation Finance added questions 1.4 through 1.6 to explain the SEC's March 17 interpretation, which carries no legal force and creates no new obligations. The FAQ defines central oversight as absent when all material operations run automatically without discretion, and when material discretion is exercised solely through broad-based governance.