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SEC Launches Regulation for Security-Based Swap Execution Facilities

Regulation SE, the last of the Title VII Dodd-Frank rulemakings, will become effective on February 13, 2024. The Securities and Exchange Commission (SEC) has taken a significant step in enhancing the regulatory landscape...more

Can It Be a Commodity if It’s Not Fungible? Evaluating NFTs Under the Commodity Exchange Act

Understanding NFTs as commodities calls for a more nuanced analysis than what their “non-fungible” label might suggest at first glance. The appropriate regulatory characterization of cryptocurrencies and digital assets...more

What’s Next for DAOs in the Wake of the Ooki Decision?

The viability of DAO structures draws attention after a judge declares that a decentralized autonomous organization is a “person” under the law. On June 8, 2023, the US District Court for the Northern District of...more

CFTC Mandates Clearing for Interest Rate Swaps on IBOR Alternatives

A new rule removes the requirement to clear IBOR-based swaps and extends mandatory clearing to swaps on IBOR alternatives. On August 12, 2022, the US Commodity Futures Trading Commission (CFTC) voted to amend its...more

Digital Commodities Consumer Protection Act Seeks to Empower CFTC

The latest bipartisan crypto bill would give the CFTC new tools and authorities to regulate digital commodities, with a focus on market integrity and consumer protection. On August 3, 2022, a bipartisan group of US...more

Responsible Financial Innovation Act Offers Clarity, Safeguards for Digital Assets - CFTC and Commodities

The CFTC would take center stage in the regulation of spot digital asset markets under Title IV of the RFIA. Latham & Watkins presents a blog series on the Responsible Financial Innovation Act, which was introduced in...more

CFTC Issues Request for Information on Climate-Related Financial Risk

The agency will use the information to take further steps to address climate risks in the commodity derivatives markets. On June 2, 2022, the Commodity Futures Trading Commission (CFTC) issued a Request for Information...more

PWG Issues Clarion Call for US Legislation on Stablecoins

The report addresses the market risks and regulatory challenges presented by stablecoins and urges Congress to act quickly. On November 1, 2021, the President’s Working Group on Financial Markets (PWG) in conjunction...more

New US Digital Assets Bill Casts Wide Net

An ambitious proposal could bring digital assets into the mainstream regulatory fold. During an eventful summer for the digital assets industry, it may have been easy to miss US Representative Don Beyer’s introduction of the...more

“SOFR First” Initiative Takes Flight

As the countdown to the LIBOR sunset enters its final six months, the CFTC staff is trying to help the market transition. With less than six months to go before the London Interbank Offered Rate (LIBOR) expires on December...more

El Salvador Christens Bitcoin as Legal Tender

A sovereign nation’s decision to adopt Bitcoin as legal tender raises interesting questions — and legal ramifications. On June 8, 2021, El Salvador’s Legislative Assembly voted to establish Bitcoin as unrestricted legal...more

What to Know About the New CFTC Cross-Border Swaps Regime

This Client Alert White Paper serves as a comprehensive guide to the new rule, which largely supersedes prior CFTC guidance that had informed market practice for over seven years. Key Points: ..The new rule became...more

CFTC Takes Action With New Climate Risk Unit

The CFTC continues to demonstrate a commitment to using its regulatory mandate to combat climate change risks to the US financial system. On March 17, 2021, the Commodity Futures Trading Commission (CFTC) announced the...more

2020 Digital Asset Regulatory Lookback (US Edition)

Regulators once again offered piecemeal guidance, while focusing on risks and enforcement. Meanwhile, innovation and institutional adoption took off. Last year, Latham & Watkins sounded a hopeful note that 2020 would provide...more

CFTC Adds Another Building Block to its Digital Asset Framework

The CFTC issues stringent guidelines for FCMs seeking to custody digital assets in connection with physically delivered futures contracts or swaps. The US Commodity Futures Trading Commission’s (CFTC’s) Division of Swap...more

CFTC Report: Climate Change Threatens Stability of US Financial System

A watershed CFTC report highlights the dangers of climate change to the US economy, and provides a broad risk-mitigation roadmap. On September 9, 2020, the US Commodity Futures Trading Commission’s (CFTC’s) Climate-Related...more

CFTC Provides Additional No-Action Relief to Smooth IBOR Transition

The relief removes regulatory obstacles and provides additional flexibility for market participants. On August 31, 2020, three divisions of the US Commodity Futures Trading Commission (CFTC) issued revised no-action...more

What the CFTC Interpretation of “Actual Delivery” Means for Crypto

The long-awaited guidance clarifies the application of the “actual delivery” exception to leveraged virtual currency transactions with retail purchasers. Earlier this year, the US Commodity Futures Trading Commission...more

COVID-19 Update: CFTC Relief for the Derivatives Market

In the face of pandemic-related disruptions, CFTC staff have relieved exchanges, dealers, intermediaries, and other market participants from certain compliance requirements. Last week, the US Commodity Futures Trading...more

COVID-19 and the Derivatives Markets: What NFA Members Need to Know

The self-regulatory organization responds to the US derivatives market’s shift to remote working arrangements. As the novel coronavirus outbreak (COVID-19) continues to spread across the globe, causing various disruptions,...more

A CFTC Helping Hand: DSIO Offers to Review Digital Asset Products

Product innovation (including in pooled investment vehicles) is encouraged, but innovation must be consistent with the law. The US Commodity Futures Trading Commission’s (CFTC’s) Division of Swap Dealer and Intermediary...more

CFTC Issues No-Action Relief for Derivatives Market IBOR Transition

While not unlimited, the relief is welcome for counterparties seeking to transition to risk-free rates for legacy swaps. The US Commodity Futures Trading Commission (CFTC) has issued no-action relief to help market...more

The CFTC Takes New Steps to Promote Innovation and ‘Explore the Unwritten Future’

The US derivatives regulator continues to foster FinTech adoption and leadership in US markets. The US Commodity Futures Trading Commission (CFTC) has affirmed its commitment to engaging the fast-moving financial...more

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