News & Analysis as of

Commodity Exchange Act (CEA) Swaps Financial Services Industry

Proskauer - Regulatory & Compliance

CFTC Clarifies that FX Window Forwards are Not “Swaps”

On April 9, 2025, the Markets Participants Division and the Division of Market Oversight (collectively, the “Divisions”) of the Commodity Futures Trading Commission (the “CFTC”) published a Staff Letter (the “Staff Letter”)...more

Proskauer - Blockchain and the Law

CFTC Issues Cease and Desist Order to Binary Options Operator Using Smart Contracts

On January 3, 2022, the Commodity Futures Trading Commission (the “CFTC”) entered an order charging Blockratize, Inc. (d/b/a Polymarket.com) (“Polymarket”) with offering off-exchange binary options contracts and failing to...more

Morgan Lewis

The Commodity Futures Trading Commission's Swaps Cross-border Guidance Proposal

Morgan Lewis on

The Dodd-Frank Act amended the Commodity Exchange Act (the Act) to create a new regulatory framework for swaps, and added Section 2(i) to require the application of the Dodd-Frank Act swap requirements to activities that...more

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