On September 22, 2022, the Commodity Futures Trading Commission (CFTC or Commission) (1) issued an order settling charges against protocol creator bZeroX, LLC and its founders, and (2).
The CFTC's theory that all persons who vote governance tokens in a DAO are effectively members of the DAO and therefore, personally are jointly and severally liable for all CEA and CFTC regulations' violations by the DAO, has not yet been affirmed by any court.
Natural persons and legal entities are potentially jointly and severally liable for all of a decentralized autonomous organization's (DAO) violations of the Commodity Exchange Act (CEA).