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CFTC Divisions Interpret "U.S. Person" Definition and U.S. Location Versus Foreign Location

A 2024 CFTC enforcement action settlement that may have introduced a new test for when the Commodity Exchange Act and the agency's regulations apply on a cross-border basis concerned then-CFTC Commissioner and now Acting CFTC...more

SEC Division of Corporation Finance: Certain U.S. Dollar-Backed Stablecoins Are Not Securities

As the Trump administration and Congress seek to establish clear digital asset regulation, uncertainty remains on whether federal agencies consider stablecoins to be "securities" under federal law....more

The CFTC Proposes Expansive Business and Governance Rules for Registered Derivatives Markets

The Commodity Futures Trading Commission ("CFTC") recently proposed new and modified conflicts of interest, fitness, and governance regulations for swap execution facilities ("SEFs") and designated contract markets ("DCMs")....more

The CFTC Proposes Rules to Protect Clearing Member Funds Held by DCOs

In Short - The Situation: In a December 13, 2023, Open Meeting, the Commodity Futures Trading Commission proposed amendments to the Commission's regulations concerning clearing member funds held by a derivatives clearing...more

Wait, There's More: The CFTC Proposes Additional Swap Reporting and Recordkeeping Amendments

The Commodity Futures Trading Commission ("CFTC") has proposed swap reporting and recordkeeping amendments that would: designate a unique product identifier ("UPI") and product classification system ("PCS") for the "other...more

The CFTC Proposes "Guidance" for Derivatives Markets on Listing Voluntary Carbon Credit Derivatives

In Short - The Background: As voluntary carbon credits ("VCCs") have grown in popularity, questions about their integrity and quality have arisen for investors and among regulators and lawmakers. For this reason, many have...more

CFTC Lacks Jurisdiction Over TRS on ETFs and Custom Baskets

In Short - The Situation: The civil action of the Commodity Futures Trading Commission ("CFTC") against Archegos Capital Management LP and its CFO is but one of many civil and criminal matters arising out of Archegos's...more

New CFTC Enforcement on Carbon Markets Misconduct

Introduction - On June 20, 2023, the United States Commodity Futures Trading Commission ("CFTC") Whistleblower Office, a unit of the agency's Division of Enforcement ("DOE"), issued a rare alert, soliciting tips about...more

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