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Congress Introduces CLARITY Act to Establish Digital Asset Regulatory Framework

U.S. House lawmakers introduced the bipartisan CLARITY Act of 2025 proposing a comprehensive regulatory framework for digital assets that would delineate agencies' oversight roles, establish a provisional registration regime...more

Regulating Digital Assets: New Market Structure Bill Builds on FIT21 Framework

The House Committees on Financial Services and Agriculture have unveiled a discussion draft for a new comprehensive U.S. crypto market structure bill, aiming to establish clear regulatory boundaries between the U.S....more

Regulating Digital Assets: FIT21 Seems to Fit the Bill

The United States lacks a regulatory framework geared toward digital assets. This raises consumer protection concerns, causes regulatory turf battles and duplicative enforcement actions, impedes innovation, and puts the...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

Federal Agencies Coordinate Action Against Celsius for Fraud and Manipulation

In Short - The Situation: In parallel federal actions, the Department of Justice ("DOJ"), Securities and Exchange Commission ("SEC"), Commodity Futures Trading Commission ("CFTC"), and Federal Trade Commission ("FTC")...more

CFTC Staff Advisory Warns That SEF Prime Brokerage Arrangements Might Require DCO Registration

This advisory is the latest Commodity Futures Trading Commission ("Commission" or "CFTC") staff action conveying a Commission or staff view that CFTC registrants conducting business in nontraditional ways may need to register...more

Economic Report of the President to the Crypto Industry: Thanks, But No Thanks

In Short - The Situation: For the first time, the Economic Report of the President (the "Report") includes a chapter on digital assets....more

California Moves to Regulate Digital Asset Exchanges and Cryptocurrency Companies

California's new Digital Financial Asset Law ("DFAL") will impose a variety of regulatory requirements on digital asset companies and cryptocurrency exchanges. Governor Newsom is expected to sign the DFAL into law, and new...more

Digital Assets Defined: SEC, CFTC, and Ancillary (Illusory?) Assets

In "Digital Assets Defined: How Lummis-Gillibrand Will Shape the Coming Fintech Debate," we provided a high-level overview of the Responsible Financial Innovation Act (the "Bill") and examined some of its significant...more

Don't Call it a Swap: The CFTC Asserts Jurisdiction Where it Shouldn't

In Short - The Situation: In a federal district court complaint against Archegos Capital Management, LP ("Archegos"), the Commodity Futures Trading Commission ("CFTC") has asserted jurisdiction over what many view as...more

7/25/2022  /  CFTC , Dodd-Frank , ETFs , Security-Based Swaps

SEC Chairman Nominee Expected to Usher in Era of Increased SEC Enforcement, Regulation

The Situation: President Joe Biden nominated Gary Gensler, former Chairman of the Commodity Futures Trading Commission ("CFTC") under the Obama administration, for Chairman of the Securities and Exchange Commission ("SEC"). ...more

Financial Regulatory Leaders Highlight Anti-Money Laundering Issues With Digital Asset Transactions - Regulators highlight AML/CFT...

On October 11, 2019, the heads of the U.S. Commodity Futures Trading Commission ("CFTC"), the U.S. Securities and Exchange Commission ("SEC"), and the Financial Crimes Enforcement Network ("FinCEN"), issued a joint statement...more

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