The Commodity Futures Trading Commission (CFTC or Commission) on November 5, 2018, in a 4-1 vote, proposed to fundamentally redesign the regulatory framework governing swap execution facilities (“SEFs”) and the trade...more
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
On August 28, 2018, the US Senate confirmed Dan M. Berkowitz and Dawn D. Stump to be commissioners of the US Commodity Futures Trading Commission (CFTC or Commission), returning the Commission to its full five-person...more
Summary: The Commodity Futures Trading Commission (“CFTC” or “Commission”) on June 4, 2018, in its first public meeting of the year, proposed three rule changes to the rules implementing the Dodd-Frank Wall Street Reform and...more
Introduction -
The Commodity Futures Trading Commission (CFTC or Commission) recently took several steps to further encourage cooperation with and self-reporting to the Commission’s Division of Enforcement (Division). In...more
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
In January of this year, the Commodity Futures Trading Commission's (CFTC or Commission) Division of Enforcement (the Division) issued revised cooperation credit guidelines for companies, and its first-ever cooperation...more
What Is an ICO?
An ICO, or initial coin offering, is the sale of virtual coins or tokens, often as a means of capital raising by startup companies that are involved in blockchain technology. Depending on the terms of the...more
8/7/2017
/ Bitcoin ,
Blockchain ,
Cryptocurrency ,
Howey ,
Initial Coin Offering (ICOs) ,
LedgerX ,
Securities Act of 1933 ,
Securities and Exchange Commission (SEC) ,
Securities Exchange Act ,
Token Sales ,
Unregistered Securities ,
Virtual Currency
The Commodity Futures Trading Commission (CFTC or Commission) has significantly amended its recordkeeping requirements, a change that will affect all entities and individuals who are required to maintain books and records...more
On May 22, 2017, the Commodity Futures Trading Commission (CFTC or Commission) amended its whistleblower rules to enhance protections for whistleblowers against retaliation and assert its own authority to bring enforcement...more
In a move that affects everyone required under its rules to maintain records, the Commodity Futures Trading Commission's (“CFTC” or “Commission”) is proposing to permit greater flexibility in the technology used for...more
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 Commodity Futures Trading Commission (CFTC or Commission) on November 3, 2016, proposed revisions (the Supplemental Proposal) to proposed Regulation Automated Trading (Reg AT). Reg AT, if adopted, will broadly affect...more
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
On September 30, 2016, Judge Analisa Torres of the Southern District of New York issued an order resolving competing motions for summary judgment in the Commodity Futures Trading Commission's (CFTC) ongoing action against...more
The Securities and Exchange Commission (SEC) recently adopted final business conduct rules for security-based swap dealers (SBSDs) and major security-based swap participants (MSBSPs) under Section 15F(h) of the Securities...more
The Securities and Exchange Commission (SEC) recently adopted final business conduct rules for security-based swap dealers (SBSDs) and major security-based swap participants (MSBSPs) under Section 15F(h) of the Securities...more
5/27/2016
/ Business Conduct Standards ,
CFTC ,
Chief Compliance Officers ,
Commodity Exchange Act (CEA) ,
Counterparties ,
Cross-Border Transactions ,
Disclosure Requirements ,
Dodd-Frank ,
Securities and Exchange Commission (SEC) ,
Securities Exchange Act ,
Security-Based Swaps ,
Swap Dealers
On Wednesday, the Securities and Exchange Commission (SEC) adopted rules that will affect firms operating in the global security-based swap market. Specifically, the SEC is requiring non-US firms that arrange, negotiate, or...more
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
1/27/2016
/ Benchmark Pricing ,
CFTC ,
Corporate Counsel ,
Enforcement Actions ,
Fraud ,
Indictments ,
Insider Trading ,
Price Manipulation ,
Regulatory Standards ,
Reporting Requirements ,
Spoofing ,
Whistleblowers
The Office of Enforcement (OE) of the Federal Energy Regulatory Commission (FERC) recently released its annual report for the past fiscal year. The report provides FY2015 statistics on the investigative and enforcement...more
I. Executive Summary -
On November 24, 2015, the Commodity Futures Trading Commission (CFTC or Commission) proposed a new regulatory regime for automated trading on US designated contract markets (DCM) (Regulation AT or...more
Beginning on December 31, 2012, swap dealers began filing applications for registration with the Commodity Futures Trading Commission (CFTC). As of October 2015, 104 entities are provisionally registered as swap dealers....more
On September 22, 2015, the Commodity Futures Trading Commission (CFTC or Commission) unanimously approved the publication of a “supplemental” proposed rule on position limits. The supplemental proposal would modify the...more
On April 29, 2015, the US Securities and Exchange Commission (SEC) proposed new rules to enhance its oversight of non-US firms’ security-based swap activity in the United States. The proposal, if adopted, will have important...more