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
While the initial swap dealer enforcement actions brought by the Commodity Futures Trading Commission (CFTC) focused on swap data reporting failures, recent enforcement efforts have focused on compliance with business conduct...more
5/26/2023
/ CFTC ,
Civil Monetary Penalty ,
Commodity Exchange Act (CEA) ,
Compliance ,
Conflicts of Interest ,
Enforcement ,
Final Rules ,
Recordkeeping Requirements ,
Swap Dealers ,
Swaps ,
Transparency
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
The Commodity Futures Trading Commission ("CFTC") recently released its enforcement results for Fiscal Year 2022 ("FY 2022"). In addition to detailing the recovery of over $2.5 billion in restitution, disgorgement, and civil...more
The CFTC's recent announcement of its settlement with a decentralized crypto protocol operator and its two individual founders, together with its complaint against the successor protocol, reflects a novel approach to...more