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Commodities Futures Trading Commission Compliance Enforcement

The United States Commodities Futures Trading Commission was created in 1974 to regulate commodity futures and option markets. The Commission’s mission is to protect market participants and the public from... more +
The United States Commodities Futures Trading Commission was created in 1974 to regulate commodity futures and option markets. The Commission’s mission is to protect market participants and the public from fraud, abuse, and systemic risk associated with derivatives subject to the Commodities Exchange Act. In 2010, as a result of the Frank-Dodd Wall Street Reform and Consumer Protection, the Commission’s role was expanded to include drafting rules for regulating the swaps marketplace. less -
A&O Shearman

CFTC Releases Guidance On Registered Non-U.S. Swap Entities Using Substituted Compliance

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On May 20, 2025, two divisions within the Commodity Futures Trading Commission (“CFTC”) — the Market Participants Division (“MPD”) and the Enforcement Division (“DOE”) — released procedures providing guidance on how the...more

Moore & Van Allen PLLC

The Desk: May Edition

On April 17, 2025, as previewed in the Division of Enforcement’s (“DoE”) February 25, 2025, “Advisory on Self-Reporting, Cooperation, and Remediation”, the Staff of the Market Participants Division (“MPD”) laid the remaining...more

Davis Wright Tremaine LLP

CFTC Divisions Issue Staff Advisory on Referrals to Division of Enforcement

On April 17, 2025, the Market Participants Division, the Division of Clearing and Risk, and the Division of Market Oversight (collectively, the "Operating Divisions") of the CFTC, along with the Division of Enforcement...more

Cadwalader, Wickersham & Taft LLP

Shifting Signals, April 2025 - Relief for Swap Dealer Pre-Trade Disclosures

On April 4, 2025, the staff of the Commodity Futures Trading Commission ("CFTC") Market Participants Division ("MPD") issued compliance relief for registered swap dealers ("SDs") from the requirement to provide the so-called...more

Nelson Mullins Riley & Scarborough LLP

“Free your mind!” — Understanding the CFTC’s New Mitigation Credit Matrix

The Commodity Futures Trading Commission (CFTC) recently issued a significant Enforcement Advisory detailing how companies and individuals can earn Mitigation Credit....more

Benesch

Mixed Messages: The Salt Typhoon Encryption Debacle

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While the balance of security, privacy, and public safety has always been a concern, recent cyberattacks have highlighted conflicting guidance by United States government officials, creating potential pitfalls for businesses....more

Bracewell LLP

Forced Enforcement? The Fine Line in the CFTC’s Approach to Market Manipulation

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On 27 August 2024, a Swiss commodity trader entered into a settlement agreement for $48 million with the US Commodity Futures Trading Commission (“CFTC”) in relation to alleged market manipulation charges. This case, rooted...more

Alston & Bird

CFTC Commissioner Warns That CCOs May Face Personal Liability

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Our Investment Funds Group reviews the implications of a Commodity Futures Trading Commission (CFTC) policy targeting chief compliance officers (CCOs) as individuals if their companies’ compliance programs fail....more

American Conference Institute (ACI)

The DOJ’s New Pilot Programs: A Bane for Compliance Programs

For years, Department of Justice officials have stressed how important chief compliance officers are as the first line of defense in fighting corporate crimes. While that’s true, compliance programs now have a competitor in...more

Vinson & Elkins LLP

New CFTC Enforcement Policy Increases Penalties to Deter Recidivists

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The U.S. Commodity Futures Trading Commission (“CFTC” or “Commission”) — the federal agency tasked with regulating the U.S. derivatives markets, which includes futures, swaps and certain kinds of options — has recently taken...more

Bracewell LLP

“Export Controls Are the New Sanctions” and Other Enforcement Trends for 2024

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2023 was a banner year in the sanctions space and regulators seem primed to continue that performance in 2024. In December 2023, numerous government officials and industry experts convened at the New York Forum on Economic...more

Davis Wright Tremaine LLP

Broker Dealer Regulatory Digest - August 2023

The following newsletter provides a roundup summarizing enforcement actions, guidance, rulemakings, and other public statements taken by a federal and/or state financial services regulatory agency, specifically focusing on:...more

Davis Wright Tremaine LLP

Swaps Enforcement Update: Business Conduct Standards for Swap Dealers and Major Swap Participants

While the initial swap dealer enforcement actions brought by the Commodity Futures Trading Commission (CFTC) focused on swap data reporting failures, recent enforcement efforts have focused on compliance with business conduct...more

American Conference Institute (ACI)

Building a Data-Driven Anticorruption Compliance Program

For more than two years now, heads of the U.S. Department of Justice have maintained a steady drumbeat that they expect companies today to have in place a sound data analytics compliance program to proactively mitigate risks....more

ArentFox Schiff

Metaverse, Blockchain & Digital Assets: 10 Legal Challenges for Companies in 2023

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With the start of the new year, the ArentFox Schiff Metaverse Industry team reviews 10 of the most pressing legal issues for companies in 2023....more

Foley Hoag LLP - White Collar Law &...

Companies Should Beware of Employees Texting Business Communications

Text messaging is convenient.  It is an informal and instant mode of communication now available through numerous apps, which allow an individual to use their synced phone, tablet, and computer to quickly fire off messages. ...more

Paul Hastings LLP

Ephemeral Messaging at the Office: Avoiding Pitfalls and Establishing Best Practices

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Users of ephemeral messaging applications may intend that their messages be—as the word “ephemeral” suggests—short lived, but the real-world consequences and legal ramifications from improper use of such apps can be anything...more

Sheppard Mullin Richter & Hampton LLP

CFTC Throws its Hat into the Corporate Compliance Arena

On September 10, 2020, the Commodities Futures Trading Commission (CFTC) issued the latest in a series of circulars regarding corporate compliance released this summer by government agencies. In June, the Criminal Division of...more

WilmerHale

Foreign Corrupt Practices Act Alert - Global Anti-Bribery Year-in-Review: 2019 Developments and Predictions

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Enforcement activity reached new heights in 2019. The year saw the two largest corporate resolutions in the history of the FCPA, corporate penalties paid to US enforcement agencies topped last year’s record levels, and...more

BakerHostetler

[Webinar] Cross-Border Regulation and Enforcement: Developments and Trends You Need to Know for 2019 - May 1st, 12:00pm ET

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Join BakerHostetler’s White Collar, Investigations and Securities Enforcement and Litigation team for a complimentary webinar on trends and predictions for 2019 in the cross-border government investigations and enforcement...more

Latham & Watkins LLP

CFTC Enters the Market for Anti-Corruption Enforcement

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New enforcement advisory encourages reporting of foreign corrupt practices that the agency intends to pursue under the Commodity Exchange Act. On March 6, 2019, the Division of Enforcement (Division) of the US Commodity...more

Foley & Lardner LLP

A Compilation of Enforcement and Non-Enforcement Actions

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Non-Enforcement - Form PF — What Purpose? SEC registered investment advisers with at least $150 million of assets under management in private funds are required to periodically file Form PF with the SEC. The...more

Morrison & Foerster LLP

Investment Management Legal + Regulatory Update - February 2015

In This Issue: - SEC Proposes Rule Requiring Hedging Disclosure - SEC Reports the Result of its Cybersecurity Sweep of Broker-Dealers and Investment Advisers - House Passes Bill to Ease Volcker Rule and Other...more

BakerHostetler

2014 Year-End Securities Litigation Enforcement Highlights

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In This Issue: - I. Supreme Court Cases Review - II. Securities Law Cases - III. Insider Trading Cases - IV. Settlements - V. Investment Adviser and Hedge Fund Cases - VI. CFTC Cases and...more

Proskauer Rose LLP

2014 Proskauer Hedge Funds and Other Private Funds Annual Review

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This year we saw a flurry of regulatory activity targeting investment advisers and hedge funds, private equity funds and other private funds (collectively, private funds). The following annual review is a summary of some of...more

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