Recently, in a wide-ranging speech, the SEC's Chief
Accountant, Wes Bricker, provided his thoughts on how the SEC
accounting staff analyzes accounting issues surrounding digital
assets and distributed ledger technology. Bricker emphasized that
companies must continue to maintain appropriate books and records,
irrespective of whether distributed ledger technology, smart
contracts or other technology-driven applications are (or are not)
used. Likewise, when accounting for digital assets, companies
should act appropriately within the parameters of the existing
requirements of the federal securities laws. Accordingly, they
should consider traditional regulations and accounting standards
such as those relating to books and records, internal accounting
controls, internal control over financial reporting, and custody.
Bricker emphasized that "[d]istributed ledger technology and
digital assets, despite their exciting possibilities, do not alter
this fundamental responsibility."