CTF Written Submission
Dragonfly
May 23, 2025
- The report argues that airdrops should not be classified as securities transactions under the Howey test, as they do not involve an investment of money, lack a common enterprise, and do not create an expectation of profits derived from the efforts of others.
- It highlights the adverse economic impact of geoblocking U.S. users from airdrops, estimating significant revenue and tax losses due to restrictive U.S. policies.
- The report recommends establishing a regulatory safe harbor for airdrops that are not intended as fundraising tools, to encourage innovation and provide clear guidelines for compliance.
Last Reviewed or Updated: May 23, 2025