To promote regulatory clarity, on August 28, 2025, the Commodity Futures Trading Commission ("CFTC")'s Division of Market Oversight issued an advisory to reaffirm its longstanding foreign board of trade ("FBOT") registration...more
Amid “recent confusion and disruption regarding whether non-US exchanges should register [with the Commodity Futures Trading Commission (CFTC or Commission)] as a designated contract market (DCM) or [foreign board of trade...more
The Commodity Futures Trading Commission (CFTC) recently announced several new staff letters and public statements with material consequences for legal and business professionals in the derivatives markets. In this alert, we...more
Toward the end of 2018, the Commodity Futures Trading Commission (CFTC) proposed significant revisions to the framework governing swap trading through swap execution facilities (SEFs) and designated contract markets (DCMs)....more
On July 27, 2016, the U.S. Commodity Futures Trading Commission (“CFTC”) proposed amendments to its rules (“Proposed Rules”) that loosen the conditions for exemption from registration as a futures commission merchant (“FCM”),...more
On November 24, 2015, the Commodity Futures Trading Commission (“CFTC”) approved the issuance of proposed rules to implement a framework of registration, reporting, recordkeeping and other compliance requirements for market...more