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US District Courts are Split on Whether the Commodity Exchange Act Preempts State Gaming Laws with Respect to Sports Event...

Derivatives exchange and prediction market KalshiEX LLC (Kalshi) was handed a litigation setback in defending its sports event contract offerings in federal court against claims brought by the State of Maryland. The District...more

CFTC Staff Issues Relief Intended to Reduce Burdens of Swap Data Notification Requirements

Staff from the Commodity Futures Trading Commission’s (CFTC) Division of Market Oversight issued No-Action Relief Letter 25-25 on July 31, 2025 to help ease compliance burdens placed on reporting counterparties in meeting the...more

CFTC Issues No-Action Relief for SEFs on Order Book Obligations

In a marked departure from its position since 2013, the Commodity Futures Trading Commission (CFTC) issued No-Action Letter 25-24 on July 30, 2025 (Letter 25-24), stating that it will not recommend enforcement action against...more

The SEC Adopts Rules Amending the Covered Clearing Agency Standards

The Securities and Exchange Commission (SEC) has recently adopted final rules applicable to SEC-registered Covered Clearing Agencies (CCA), which are intended to help protect investors by enhancing CCAs’ risk management...more

Copy and Paste: The SEC Adopts Security-Based Swap Execution Facility Rules that Closely Resemble Existing CFTC Swap Execution...

After issuing two proposals, the Securities and Exchange Commission (SEC) adopted final rules (Final Rules) to establish its trading regime for security-based swaps (SBS) as required under the Dodd-Frank Wall Street Reform...more

Financial Services Industry Year in Review: Regulatory Enforcement and Litigation Trends in 2021 and Beyond

Just like the rest of us, the financial services industry wasn't immune from the numerous and unprecedented pandemic-related challenges over the past year. Through our annual Financial Markets Litigation and Enforcement...more

CFTC Expanding Anti-Manipulation Powers to Punish Misrepresentations to Futures Exchanges and FCMs

Recent Commodity Futures Trading Commission (CFTC) enforcement actions rely on the anti-manipulation provisions of the Dodd-Frank Wall Street Reform and Consumer Protection Act (Dodd-Frank) to punish misstatements made to...more

CFTC Adopts New Rules on Position Limits for Derivatives

The Commodity Futures Trading Commission (CFTC) voted to adopt new rules on position limits (Final Rules) in an open meeting on October 15. Once effective, the Final Rules will implement one of the remaining key provisions of...more

CFTC Adopts New Position Limits Requirements

On October 15, the Commodity Futures Trading Commission adopted new rules on position limits. The new rules mark an important step forward in a decade-long journey to enact one of the remaining key provisions of Title VII of...more

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