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Digital Assets Enforcement Actions Swap Dealers

McDermott Will & Emery

CFTC Staff Letter 25-14: What Is a “U.S. Person”?

On May 21, 2025, the Commodity Futures Trading Commission’s (CFTC) Market Participants Division and Division of Market Oversight jointly issued Staff Letter 25-14 in response to a request from SCB Limited, a Bahamas-based...more

WilmerHale

CFTC Update: The First 30 Days

WilmerHale on

The CFTC has seen a significant amount of activity since the inauguration of President Donald Trump on January 20. Chairman Rostin Behnam resigned as Chairman and as a Commissioner. Caroline Pham was elected Acting Chairman...more

Guidepost Solutions LLC

Emerging Expectations from the Latest Enforcement Actions Over Off-Channel Communications

Since December 2021, the U.S. Securities and Exchange Commission (SEC) and Commodity Futures Trading Commission (CFTC) have levied almost $3.0 billion in penalties for longstanding failures by 39 broker-dealers, swap dealers,...more

WilmerHale

CFTC 2020 Enforcement and Regulatory Developments and a Look Forward

WilmerHale on

2020 saw continuity in CFTC leadership, programs, and direction from 2019. Overall, the Commission enjoyed an unusually heavy rulemaking calendar and continued the direction of its enforcement program from 2019. On the...more

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