Blockchain, virtual currencies and the businesses associated with them are developing in largely uncharted regulatory territory. This does not mean, however, that regulators are ignoring the technology and asset class. The U.S. District Court for the Eastern District of New York (EDNY) recently handed the CFTC a significant victory, ruling that virtual currencies are commodities under the Commodity Exchange Act, thereby giving the CFTC jurisdiction over fraudulent conduct involving them. See “What Fund Managers Investing in Virtual Currency Need to Know About NFA Reporting Requirements and the CFTC’s Proposed Interpretation of ‘Actual Delivery’” (Mar. 1, 2018); and “Virtual Currencies Present Significant Risk and Opportunity, Demanding Focus From Regulators, According to CFTC Chair” (Feb. 8, 2018). This article details the facts and circumstances leading up to the enforcement action and the EDNY’s reasoning. For more on blockchain, see “How Blockchain Will Continue to Revolutionize the Private Funds Sector in 2018” (Jan. 4, 2018); as well as our three-part series on blockchain and the financial services industry: “Basics of the Technology and How the Financial Sector Is Currently Employing It” (Jun. 1, 2017); “Potential Uses by Private Funds and Service Providers” (Jun. 8, 2017); and “Potential Impediments to Its Eventual Adoption” (Jun. 15, 2017).