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Second Circuit Breathes New Life Into Conduct And Effects Test

The Situation: Since the Supreme Court decided Morrison v. National Australia Bank Ltd. ("Morrison") in 2010 and rejected the Second Circuit's "conduct and effects test," the Second Circuit has grappled with the issue of...more

Tenth Circuit Holds Federal Securities Laws Apply Extraterritorially In Enforcement Actions

The Situation: The U.S. Court of Appeals for the Tenth Circuit recently addressed the issue of whether the antifraud provisions of the federal securities laws apply extraterritorially in enforcement actions commenced by the...more

Commodity Exchange Act: Key Decisions from 2018 and Enforcement Trends to Monitor in 2019

2018 was an interesting year for market participants subject to the Commodity Exchange Act ("CEA"), with federal appellate courts issuing three noteworthy decisions involving claims under the CEA. The Commodity Futures...more

Trial Loss Unlikely to Significantly Alter CFTC Efforts to Police Market Manipulation

The Situation: Judge Richard Sullivan of the Southern District of New York ("SDNY") recently issued a post-trial decision in a market manipulation action brought by the Commodity Futures Trading Commission ("CFTC") in...more

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