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Derivatives and Securities Dealers' Pre-Hedging of Client Trades Faces Potential New Rules

Derivatives and securities dealers and some of their market users are locked in a potentially consequential debate over what legal standards should be adopted to govern pre-hedging (also called “pre-positioning” or...more

The CFTC’s New Advisory on Self-Reporting, Cooperation and Remediation

In an advisory announced February 25, 2025, the Division of Enforcement of the Commodity Futures Trading Commission (CFTC or Commission) announced a new regime for assessing cooperation credit in determining fines in the...more

CFTC, DOJ and SEC Announce Landmark Prosecutions Alleging Fraud in Connection With Voluntary Carbon Credits

On October 2, 2024, the Commodity Futures Trading Commission (CFTC), the US Department of Justice (DOJ), and the Securities and Exchange Commission (SEC) announced parallel prosecutions charging a carbon credit project...more

Compliance Take Heed: CFTC Fines Tyson Foods $1.5 Million for Position Limits, Reporting, and Record Keeping Violations

On August 13, 2021, the Commodity Futures Trading Commission (“CFTC” or “Commission”) approved a settlement to resolve allegations that Tyson Foods, Inc. (“Tyson”) exceeded the CFTC’s position limits for soybean meal futures...more

Who Is Watching The Watchmen?: CFTC Penalizes Registrant For Outsourced IT Security Lapses

On February 12, 2018, the Commodity Futures Trading Commission (CFTC) settled charges against AMP Global Clearing LLC (AMP), a futures commission merchant (FCM), for the company’s failure to adequately supervise one of its IT...more

FERC Enforcement – What to Expect in 2015

The Federal Energy Regulatory Commission’s (FERC’s) Office of Enforcement (Enforcement) recently released its annual report on enforcement activities for 2014. As is typical, Enforcement identified its primary concerns as...more

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