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CFTC Divisions Interpret "U.S. Person" Definition and U.S. Location Versus Foreign Location

A 2024 CFTC enforcement action settlement that may have introduced a new test for when the Commodity Exchange Act and the agency's regulations apply on a cross-border basis concerned then-CFTC Commissioner and now Acting CFTC...more

SDNY Issues Two Rulings in Closely Watched Enforcement Action Against Ripple Labs

The SEC's Enforcement Action Against Ripple - In December 2020, the SEC commenced an enforcement action against Ripple and two of its senior executives alleging that the defendants violated Section 5 of the Securities Act...more

SDNY Issues Two Rulings in Closely Watched Enforcement Action Against Ripple Labs

The SEC's Enforcement Action Against Ripple - In December 2020, the SEC commenced an enforcement action against Ripple and two of its senior executives alleging that the defendants violated Section 5 of the Securities Act of...more

SPAC Founders, Beware: SEC Targets Founders Shares

The Securities and Exchange Commission ("SEC") charges a special purpose acquisition company ("SPAC"), its CEO, and sponsor, as well as the merger acquisition target, with securities law violations, resulting in significant...more

CFTC Issues Advisory on Self-Reporting of Foreign Corrupt Practices for Non-Registrants

The Advisory is part of the agency's broader commitment to provide "incentives for companies and individuals to engage in ethical corporate behavior." On March 6, 2019, the U.S. Commodity Futures Trading Commission...more

Second Circuit Concludes Commodity Exchange Act Claims Accrue When Plaintiffs Learn Of Their Injuries

Under the "discovery accrual rule" discovery of the injury starts the clock for statute of limitations purposes. On February 28, 2019, the Second Circuit issued an important decision regarding the statute of limitations...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

CFTC Announces Insider Trading Task Force and New Insider Trading Case

Commodity brokerage firms need to be vigilant as the CFTC signals increased policing and prosecution of insider trading. The Commodity Futures Trading Commission ("CFTC") filed a complaint on September 28, 2018, in the...more

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