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"Decentralization" is a concept that has consistently
vexed the entire blockchain-enabled ecosystem in the U.S.,
including its counsel and regulators, wherein a lack of clarity on
the exact definition of decentralization has left relevant
stakeholders routinely talking past one another. As such, market
participants have been eagerly waiting for the U.S. Securities and
Exchange Commission (the
SEC) to explain the
agency's understanding of what it means for a
blockchain-enabled network to be "sufficiently
decentralized." Based on the SEC's recent enforcement
action, it looks like the agency is getting ready to take a deep