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CFTC 2022 Enforcement and Regulatory Developments and a Look Forward

The year 2022 was a historic year for the Commodity Futures Trading Commission (“CFTC” or the “Commission”). Just four days into the new year, on January 4, 2022, Rostin Behnam was sworn in as the CFTC’s 15th Chairman. Three...more

SEC and CFTC Signal Push for Broader Authority Over Digital Asset Markets

The Securities and Exchange Commission (SEC) and the Commodity Futures Trading Commission (CFTC) recently announced enforcement actions that reflected sweeping, and previously unarticulated, views of their respective...more

CFTC 2020 Enforcement and Regulatory Developments and a Look Forward

2020 saw continuity in CFTC leadership, programs, and direction from 2019. Overall, the Commission enjoyed an unusually heavy rulemaking calendar and continued the direction of its enforcement program from 2019. On the...more

CFTC Enforcement Division Issues Compliance Program Guidance

On September 10, 2020, the Commodity Futures Trading Commission’s (CFTC, or the Commission) Division of Enforcement (Division) director issued a memorandum to Division staff setting forth a framework for evaluating the...more

2018 CFTC Year-In-Review

For the Commodity Futures Trading Commission (CFTC or Commission), 2018 was characterized by (1) an active enforcement program emphasizing cooperation and self-reporting, (2) increasing cross-border tension over supervision...more

Court Again Rejects a CFTC Manipulation Claim

Introduction: On November 30, 2018, the Southern District of New York issued an opinion reaffirming the long-standing rule that traders cannot be found liable for illegal market manipulation when their trading was motivated...more

New Commission Moves Quickly on Enforcement

Within a week of the ceremonial swearing in of its last commissioner, the now fully formed Commodity Futures Trading Commission (Commission or CFTC) issued 17 enforcement orders and filed one complaint. These initial...more

2017 CFTC Year-in-Review and a Look Forward

In 2017, under the leadership of new Chairman J. Christopher Giancarlo, the Commodity Futures Trading Commission (CFTC or Commission) adopted a notable shift in its enforcement priorities and regulatory agenda. In March,...more

2016 CFTC Year-in-Review and a Look Forward

In 2016, the Commodity Futures Trading Commission (CFTC or Commission) continued to pursue high-profile enforcement cases and to test its new enforcement authority under the Dodd-Frank Wall Street Reform and Consumer...more

The Manipulation Standard And A Setback For CFTC

On Sept. 30, 2016, Judge Analisa Torres of the Southern District of New York issued an order resolving competing motions for summary judgment in the U.S. Commodity Futures Trading Commission's ongoing action against Donald R....more

CFTC Alert: 2015 CFTC Year-in-Review, and a Look Forward

CFTC continues to bring high-profile, large-penalty enforcement cases; begins bringing cases to enforce Dodd-Frank Act implementing regulations; and embarks on post-Dodd-Frank Act regulatory initiatives. ...more

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