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The GENIUS Act Ushers in a New Era for Stablecoin Regulation

On July 17, 2025, Congress passed the Guiding and Establishing National Innovation for U.S Stablecoins Act (“GENIUS Act” or “Act”) – a landmark piece of legislation that received bipartisan support and was signed into law by...more

UK and US Cryptoasset Regulation - What direction next?

At present, Cryptoassets are largely unregulated in the UK. However, the growth of crypto cannot be ignored and many argue that regulators need to take action to ensure adequate consumer protections are in place and to...more

Fifth Circuit Rules OFAC Cannot Sanction Tornado Cash: Loper Bright Hamstrings OFAC’s Campaign Against Crypto Laundering

Shortly before Thanksgiving, a panel of the United States Court of Appeals for the Fifth Circuit ruled that the Office of Foreign Assets Control (“OFAC”) did not have the authority to sanction Tornado Cash, which offers a...more

2024 CFTC Enforcement: Agency Celebrates Record Monetary Relief

On December 4, 2024, the Commodity Futures Trading Commission (“CFTC”) released its enforcement results for Fiscal Year 2024 (“FY 2024”), showcasing record awards of monetary relief totaling more than $17.2 billion....more

SEC Enforcement Tea Leaves: Expected Priorities in the Second Trump Administration

How will President-elect Trump’s reelection impact the SEC’s enforcement priorities? We looked for clues from the first Trump Administration’s Enforcement program, and also from the agency’s current Republican Commissioners....more

CFTC’s Consent Order with Trafigura Trading: When Inaction Becomes Action

On June 17, 2024, the CFTC filed a consent order against Trafigura Trading LLC, requiring the company to pay a $55 million civil monetary penalty and implement remedial measures. The CFTC’s order details three violations of...more

CFTC’s Updated Large Trader Report Rule Leaves Important Questions Unanswered

Last week, the CFTC updated its large trader position reporting rules for futures and options. First proposed in June 2023, this much-needed change modernizes a rule that had gone largely unchanged since the 1980s....more

CFTC’s Annual Enforcement Results: Another Blockbuster Year

The Commodity Futures Trading Commission ("CFTC") recently released its enforcement results for Fiscal Year 2023 ("FY 2023"), which ran from October 1, 2022, through September 30, 2023. ...more

Driving Force - More fines, more admissions, more monitors: what is the future of CFTC enforcement?

In a recent speech given at New York University’s School of Law, the Commodity Futures Trading Commission’s (CFTC’s) Director of Enforcement, Ian McGinley, unveiled a new advisory concerning penalties, monitors and admissions...more

First “Insider Trading” Case Goes From Bad to Worse for CFTC

On January 8, 2024, the U.S. Court of Appeals for the Fifth Circuit reversed a jury’s verdict in a Commodity Futures Trading Commission (“CFTC”) enforcement action against EOX Holdings, L.L.C. (“EOX”) and its employee, Andrew...more

The CFTC is Not Your Friend: More Penalties, More Monitors and More Admissions

New guidance from the Commodity Futures Trading Commission[i] may significantly change the calculus for firms considering whether to settle an enforcement action. Requiring admission of wrongdoing in a greater number of...more

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