On March 17, 2026, the SEC and CFTC jointly issued the Application of the Federal Securities Laws to Certain Types of Crypto Assets and Certain Transactions Involving Crypto Assets (“Interpretation”)[1], providing the most comprehensive guidance to date on how federal securities laws and the Howey[2] investment contract test apply to crypto assets. The Interpretation is the first product of “Project Crypto,” a joint SEC-CFTC harmonization effort announced in January 2026, and marks a deliberate departure from the prior “regulation by enforcement” approach. This alert summarizes the key takeaways for financial services firms. The core message: many crypto assets are not securities, but how they are offered and sold still…