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CFTC Asserts Jurisdiction Over DAOs in Groundbreaking Enforcement Action

On 22 September 2022, in its first-ever enforcement action against a decentralized autonomous organization (DAO), the Commodity Futures Trading Commission (CFTC) alleged that certain automated crypto transactions conducted on...more

Know Your Limits: The CFTC Adopts Position Limits for Derivatives Related to Energy, Agriculture, and Metals Products

INTRODUCTION - The Commodity Futures Trading Commission (CFTC) recently voted 3–2, along party lines, to approve a final rule (Final Rule) regarding position limits for certain futures contracts and economically equivalent...more

The CFTC's Enforcement Division Again Puts Market Participants on Notice About Its Expectations Concerning Compliance Programs

Continuing to press the message that implementing and enforcing an effective compliance program is a business imperative, not an optional “best practice,” on 10 September 2020, the Commodity Futures Trading Commission (CFTC)...more

The CFTC Once Again Proposes Position Limits for Derivatives

INTRODUCTION - On January 30, 2020, the Commodity Futures Trading Commission (“CFTC” or “Commission”) approved a proposed rule (the “Proposed Rule”) for new and amended regulations concerning speculative position limits for...more

Reconsidering CFTC Position Limits - Looking Back in Order to Look Forward to the Upcoming CFTC Position Limit Proposal

As the new Chairman of the Commodity Futures Trading Commission (“CFTC” or the “Commission”), Chairman Tarbert’s short-term agenda is expected to include new position limit rules related to physical commodities....more

CFTC Issues No-Action Relief for Floor Traders to Exclude SEF-Executed Cleared Swaps from the Swap Dealer De Minimis Calculation

Introduction - On June 27, 2019, the Commodity Futures Trading Commission (“CFTC”) issued no-action relief for floor traders to “encourage new liquidity providers to trade cleared swaps on registered venues without...more

Another Cop on the International Beat: The CFTC Announces Expanded Focus on Foreign Corruption

On Wednesday, the U.S. Commodity Futures Trading Commission (“CFTC” or the “Commission”) became the latest government agency to formally set its sights on foreign corruption. ...more

The SEC Sends a Stern Reminder That It Is Serious About Punishing “Spoofing” and “Layering” Schemes in the Securities Markets

On March 10, 2017, the U.S. Securities and Exchange Commission (“SEC”) filed a civil complaint in the U.S. District Court for the Southern District of New York alleging that a Ukraine-based trading firm committed securities...more

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