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CFTC Proposes Interpretation of “Actual Delivery” for Virtual Currencies

The proposed interpretation would further clarify the CFTC’s jurisdiction over virtual currency platforms that facilitate retail commodity transactions. On December 15, 2017, the US Commodity Futures Trading Commission...more

CFTC Brings Significant Enforcement Action Against Online Cryptocurrency Exchange

The action reflects the CFTC’s expanded jurisdiction and provides further clarity on what constitutes “actual delivery” in cryptocurrency trading. On June 2, 2016, the US Commodity Futures Trading Commission (CFTC)...more

Dodd-Frank Almost 6 Years Later: Where Are We Now? Energy-Related Derivatives Regulation

In the almost six years since the enactment of the Dodd-Frank Wall Street Reform and Consumer Protection Act (Dodd-Frank Act), the US Commodity Futures Trading Commission (CFTC) has, in large part, finalized its rulemakings...more

Dodd-Frank 5 Years Later: Where Are We Now? Derivatives Regulation for Asset Managers

Assessing the practical implications of derivatives regulations for investment advisers and investment funds of: position limits and aggregation rules, uncleared swaps margin rules, etc. Since the enactment of the...more

Prudential Regulators Are First to Finalize Uncleared Swap Margin Rules

While the rules provide some clarity, the global market still awaits the finalization of the CFTC and the European margin rules. With the clock ticking on the countdown to finalization of uncleared swap margin rules...more

CFTC Proposes Cross-Border Application of Margin Requirements for Uncleared Swaps

The CFTC has proposed rules that would define the reach of Dodd-Frank Act margin requirements in cross-border swap transactions. On June 29, 2015, the US Commodity Futures Trading Commission (CFTC) proposed regulations...more

Updated: CFTC Clarifies Regulation of Forward Contracts with Embedded Volumetric Optionality

With recent release, the CFTC hopes to eliminate market uncertainty on forward contracts with embedded volumetric optionality. UPDATE (June 18, 2015): On May 12, 2015, the CFTC adopted the Proposal as proposed (as used...more

SEC Proposes Additional Cross-Border Rules for Security-Based Swaps

If finalized, the proposed rule would be the SEC’s second major step toward finalizing the cross-border rules for security-based swaps under the Dodd-Frank Act. On April 29, 2015, the US Securities and Exchange...more

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