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Commodities Futures Trading Commission Compliance Enforcement Actions

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 -
Husch Blackwell LLP

CFTC Enforcement Division Issues Framework for DOJ Criminal Referrals

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On July 9, 2025, the Commodity Futures Trading Commission (CFTC) Division of Enforcement (DOE), acting pursuant to a recent executive order (EO), issued an advisory letter outlining its new policy for referring criminally...more

K&L Gates LLP

NFA Proposes Guidance on Diligent Supervision of Associated Persons

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UPDATE: On 1 May 2025, NFA withdrew Interpretive Notice 9083. The guidance remains available on NFA’s website for industry participants’ review....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

Regulation in Flux, March 2025 - CFTC Staff Withdraws Advisory on Swap Execution Facility Registration Requirement

On March 13, 2025, the Commodities Futures Trading Commission (“CFTC”) issued Letter 25-05, withdrawing controversial and much-criticized Staff Letter 21-19 (“SEF Registration Advisory”), which was issued September 29, 2021...more

Akin Gump Strauss Hauer & Feld LLP

CFTC Acting Chair Caroline D. Pham Announces CFTC’s 30-Day Enforcement Sprint

On February 25, 2025, the U.S. Commodity Futures Trading Commission (CFTC) released an enforcement advisory regarding the impact of self-reporting, cooperation and remediation in enforcement cases (the “Enforcement...more

Husch Blackwell LLP

Acting CFTC Chairman Caroline D. Pham Releases Additional Enforcement Guidance

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On March 11, acting Commodity Futures Trading Commission (CFTC) Chairman Caroline D. Pham offered insight into the regulator’s February 25, 2025 advisory in a keynote addressed delivered at Boca, the annual International...more

Paul Hastings LLP

The CFTC Is “in the Mode to Make Deals” (and Other Updates on the Commission)

Paul Hastings LLP on

Yesterday, Acting CFTC Chairman Caroline Pham created a two-week window to bring “reasonable settlement offers” to the commission. Based on my conversations with her and others, I believe the CFTC is in “deal mode” and is...more

Seward & Kissel LLP

CFTC’s Spring Cleaning: Let's Make a Deal (Quickly)

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The Commodity Futures Trading Commission (CFTC) has a lot on its plate—too many enforcement cases, not enough time, and a limited appetite for dragging out every compliance misstep. So, yesterday, at the International Futures...more

Mayer Brown

CFTC’s Division of Enforcement Issues New Advisory on Self-Reporting, Cooperation and Remediation

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AT A GLANCE - New guidance on self-reporting, cooperation, and remediation was recently released by the Commodity Futures Trading Commission’s Division of Enforcement (CFTC). The CFTC’s advisory includes tiered scales for...more

Cadwalader, Wickersham & Taft LLP

Amid Chaos, Regulatory Change Continues Apace, March 2025 - New CFTC Enforcement Guidance

On February 25th, 2025, the Commodity Futures Trading Commission’s (“CFTC”) Division of Enforcement (“Division”) issued a long-awaited advisory (the “Advisory”) regarding its evaluation of how a company’s or individual’s...more

Jenner & Block

Client Alert: CFTC Issues New Enforcement Advisory Aiming to Incentivize Self-Reporting and Cooperation

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On February 25, 2025, the Division of Enforcement (the “Division”) of the Commodity Futures Trading Commission (the “CFTC” or “Commission”) issued an Enforcement Advisory which quantifies the monetary credit that entities can...more

Lowenstein Sandler LLP

Crypto Brief - Lowenstein Crypto Newsletter - March 6, 2025

Lowenstein Crypto advises leading digital asset and cryptocurrency projects, exchanges, and trading firms. Our practice covers regulatory advice, transactions and structuring advice, investigations, and adversarial matters...more

Bracewell LLP

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

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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

Husch Blackwell LLP

CFTC Enforcement Division Releases Mitigation Credit Matrix for Self-Reporting, Cooperation, and Remediation

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On February 25, 2025, the Commodity Futures Trading Commission (CFTC) signaled a shift in its enforcement approach by releasing new guidance on the role self-reporting and cooperation play in its assessment of penalties. The...more

Alston & Bird

Enter the Matrix: CFTC’s New Framework for Self-Reporting, Cooperation, and Remediation

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Our White Collar, Government & Internal Investigations Group analyzes new enforcement guidance from the Commodity Futures Trading Commission (CFTC) that aims to incentivize self-reporting of potential violations....more

Baker Botts L.L.P.

CFTC Issues Enforcement Advisory Adopting New Approach for Consideration of Self-Reporting, Cooperation, and Remediation

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On February 25th, the Commodity Futures Trading Commission (CFTC or Commission) adopted a new approach for how the Division of Enforcement (Division) will assess self-reporting, cooperation, and remediation efforts when...more

Morrison & Foerster LLP

New CFTC Advisory Incentivizes Self-Reporting, Cooperation, and Remediation

The Advisory sets out factors that the Enforcement Division will use to rate self-reporting and cooperation. This rating places a company or individual within a “tier” used to determine the Mitigation Credit amount available....more

A&O Shearman

Carbon fraud is on the rise—but so is the regulatory counteroffensive

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At COP29 in Baku, new rules were adopted for carbon markets under Article 6 of the Paris Agreement. These rules are meant to increase the transparency of the country-to-country trading of carbon credits under Article 6.2....more

Skadden, Arps, Slate, Meagher & Flom LLP

CFTC Announces New Enforcement Advisory on Self-Reporting, Cooperation and Remediation

On February 25, 2025, the Division of Enforcement of the Commodity Futures Trading Commission (CFTC or the Commission) issued an advisory to Division staff on how to evaluate self-reporting, cooperation and remediation credit...more

Lowenstein Sandler LLP

Crypto Brief - Lowenstein Crypto Newsletter - February 20, 2025

Lowenstein Sandler LLP on

Lowenstein Crypto advises leading digital asset and cryptocurrency projects, exchanges, and trading firms. Our practice covers regulatory advice, transactions and structuring advice, investigations, and adversarial matters...more

Pietragallo Gordon Alfano Bosick & Raspanti,...

Will the CFTC’s New Top Cop Usher in an Era of Increased Investigation and Related Rewards for Whistleblowers?

On February 14, 2025, the Commodity Futures Trading Commission (CFTC) signaled some “love” for whistleblowers and the future of the CFTC’s whistleblower program when announcing that Brian Young had been appointed as a new...more

A&O Shearman

Federal Departments And Regulatory Agencies Move Quickly To Reorganize Structure And Policy Goals Following Introduction Of New...

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Department of Justice - One day after her confirmation on February 4, 2025, Attorney General Pam Bondi issued two Memos addressed to the entire Department of Justice (DOJ), which curtailed enforcement under the Foreign...more

Moore & Van Allen PLLC

The Desk - February Edition

January is at least eight weeks – I’m certain of it. Now that it’s February we know who’s running the CFTC and its different Divisions, for the time being. Acting Chair Pham comes to her position with a long history of...more

Davis Wright Tremaine LLP

New Administration Outlook: A Possible Roadmap to What's Ahead for the CFTC Under New Leadership

On January 20, 2025, the Commodity Futures Trading Commission ("CFTC") unanimously elected Commissioner Caroline D. Pham as acting chairman. The Administration has not yet identified who will be nominated for the position of...more

Morrison & Foerster LLP

Extended Compliance Date for Recent Form PF Amendments

The new year always marks the start of a busy regulatory filing season for registered investment advisers, including investment advisers that file Form PF (“Form PF Filers”). This year could be especially challenging since,...more

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