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
6/2/2025
/ CFTC ,
Commodity Exchange Act (CEA) ,
Cross-Border Transactions ,
Derivatives ,
Enforcement Actions ,
Financial Markets ,
Financial Services Industry ,
Interpretive Letters ,
Investment Portfolios ,
Jurisdiction ,
Market Participants ,
New Guidance ,
Popular ,
Regulatory Oversight ,
Regulatory Requirements ,
Settlement
On April 17, 2025, the Commodity Futures Trading Commission's ("CFTC") operating divisions ("Divisions") provided guidance in an advisory on the criteria they will use when determining whether to refer self-reported...more
As Congress moves to enact comprehensive stablecoin legislation under the Trump administration, both the Senate and the House of Representatives have updated their respective payment stablecoin bills. Our recent Commentary...more
3/18/2025
/ Anti-Money Laundering ,
Bank Secrecy Act ,
Digital Assets ,
Financial Institutions ,
Financial Regulatory Reform ,
Financial Services Committee ,
Financial Services Industry ,
Financial Transactions ,
FinTech ,
Payment Systems ,
Proposed Legislation ,
Regulatory Agenda ,
Regulatory Requirements ,
Stablecoins ,
U.S. Treasury
The Commodity Futures Trading Commission's ("CFTC") new enforcement advisory introduces several major changes in policy and a matrix helping those facing potential or actual CFTC investigations quantify the extent to which...more
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
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
12/14/2023
/ Carbon Emissions ,
Carbon Pricing ,
CFTC ,
Derivatives ,
Designated Contract Markets (DCMs) ,
Energy Market ,
Financial Institutions ,
Financial Markets ,
Financial Services Industry ,
Greenhouse Gas Emissions ,
Investment ,
Proposed Guidance ,
Risk Management ,
SEFs