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New Administration Outlook: A Possible Roadmap to What's Ahead for the CFTC Under New Leadership

On January 20, 2025, the Commodity Futures Trading Commission ("CFTC") unanimously elected Commissioner Caroline D. Pham as acting chairman. The Administration has not yet identified who will be nominated for the position of...more

New Administration Outlook: SEC Announces Creation of Crypto Task Force

On January 21, 2025, Acting SEC Chairman Mark Uyeda announced the creation of a crypto Task Force dedicated to developing a "comprehensive and clear regulatory framework for crypto assets." Acting Chairman Uyeda tasked...more

New Administration Outlook: Trump Administration Transforms U.S. Policy on Digital Assets

The Trump Administration has embarked on a fundamental shift on how the United States approaches digital assets—in marked contrast with the Biden Administration's policies—likely changing the prospects of the crypto market in...more

Digital Chamber Urges New Digital Asset Regulatory Priorities

The Digital Chamber ("TDC"), an organization dedicated to championing Bitcoin, digital assets, and blockchain innovation, recently released a proposed agenda for the SEC's new chair and commission titled TDC's "2025 SEC...more

CFTC Releases Its Enforcement Results for FY 2024 Showing an All-Time High for Monetary Relief

On December 4, 2024, the CFTC's Division of Enforcement ("Division") released its enforcement results for Fiscal Year 2024. The results reflected an all-time high for monetary relief, mainly from its resolution of off-channel...more

"Operation Chokepoint 2.0": De-banking policies and the adverse use of reputational risk in bank supervision

As we have previously noted, we expect that the second Trump Administration will be significantly more favorable to crypto than the Biden Administration, especially with the recent appointment of David Sacks as the...more

A New Prologue for Crypto – A Practical Analysis and Proposal in the Name of Efficiency and Sound Regulatory Policy

"The United States, with its history of welcoming innovators, has a large reserve of good will. In a country that ever aspires to improve with time, people are hopeful that bad policy approaches can change. This hope is not...more

CFTC Division of Enforcement, FY 2023: A Year in Review and Looking Ahead

On November 7, 2023, the Division of Enforcement ("Division") of the United States Commodity Futures Trading Commission ("CFTC") released its annual report of the results of its enforcement efforts, announcing that it had...more

CFTC Issues Staff Advisory Letters on DCO Regulation: Prime Brokerage Arrangements and Digital Assets

In May 2023, the Division of Clearing and Risk ("DCR") of the Commodity Futures Trading Commission ("CFTC") issued two Staff Advisory letters addressing areas of regulatory focus related to Derivatives Clearing Organizations...more

CFTC Action Against Decentralized Digital Asset Manipulation Is First of Its Kind

The Commodity Futures Trading Commission ("CFTC") recently filed a novel civil enforcement action against Avraham "Avi" Eisenberg in the U.S. District Court for the Southern District of New York, charging Eisenberg with a...more

Court Rules Digital Asset DAOs Can Be Sued by the CFTC

In September 2022, the Commodity Futures Trading Commission (CFTC) filed a complaint in federal district court in San Francisco against Ooki DAO, a decentralized autonomous organization (DAO), alleging violations of the...more

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