The staff of the Division of Corporation Finance at the US Securities and Exchange Commission issued a no-action letter on 3 November 2026, responding to a request submitted by Digital Asset Holdings, LLC on 30 October 2026. The letter is a staff position rather than a Commission rule or order, and the Division stated that it does not express any legal conclusion on the issues presented.
The request asked the Division to apply the Commission interpretation titled Application of the Federal Securities Laws to Certain Types of Crypto Assets and Certain Transactions Involving Crypto Assets, Release Nos. 33-11412 and 34-105020, 91 Fed. Reg. 13714 (23 March 2026). That interpretation defines a central party as a person, entity, or group of persons or entities having operational, economic, or voting control of a crypto system. The registration provisions at issue are section 5 of the Securities Act of 1933 and section 12(g) of the Securities Exchange Act of 1934, and the relevant definitions of a security sit at section 2(a)(1) of the Securities Act and section 3(a)(10) of the Exchange Act.
Relying on the representations made in the request, the Division said it is of the view that Canton Coin is a digital commodity as that term is described in the interpretation. It added that it would not recommend enforcement action if Canton Coin is minted programmatically, without registration, by Super Validators, Validators and application providers operating in the manner described. Those are the node operators running the Global Synchronizer, the parties supplying validation infrastructure, and the businesses building applications on the Canton Network.
The position rests on representations that the Canton Network was functional upon launch, that no person holds operational, economic or voting control of it, that changes to protocol rules and economic parameters require approval by at least two thirds of Super Validator node operators, and that there was no initial coin offering, pre-mine or pre-launch allocation. The Division stated that any different facts or conditions might require it to reach different conclusions.
Licentium advises token issuers, network operators and infrastructure providers on how US securities law applies to digital assets and to the mechanics by which those assets are created and distributed. Work we undertake includes assessing whether a token's issuance and governance arrangements sit within the Commission's crypto asset interpretation, preparing no-action and interpretive requests, and structuring minting and reward mechanics to match the representations a regulator will rely on.