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Enforcement Actions Commodities Futures Trading Commission Financial Services Industry

DLA Piper

Blockchain and Digital Assets News and Trends – July 2025

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This periodic bulletin is designed to help companies identify important legal developments governing the use and acceptance of blockchain technology, smart contracts, and digital assets....more

Pillsbury Winthrop Shaw Pittman LLP

Judge Starr’s Ruling in Metals.com Case Raises Jurisdictional Questions About CFTC Authority

A recent ruling by a Texas federal court adopts a narrow, textually driven reading of the Commodity Exchange Act, questioning whether gold and silver bullion are “commodities” within the statute’s scope....more

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

Orrick, Herrington & Sutcliffe LLP

CFTC Commissioner discusses AI in financial services

On July 8, CFTC Commissioner Kristin Johnson remarked on the rapid integration of AI and machine learning technologies specific to the financial sector. To deter bad actors, the Commissioner noted how using AI to commit fraud...more

BakerHostetler

DSIR Deeper Dive: Information Governance - Communication Retention Challenges and a Return-to-Office Reaction

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Let’s say, once upon a time, you worked from home during the pandemic. If so, did you use a variety of communication methods (perhaps switching among different platforms, never sure which camera or microphone would be...more

Troutman Pepper Locke

Troutman Pepper Locke Weekly Consumer Financial Services Newsletter – June 2025 # 3

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To keep you informed of recent activities, below are several of the most significant federal and state events that have influenced the Consumer Financial Services industry over the past week....more

Moore & Van Allen PLLC

The Desk: June Edition

While there was some—albeit limited—Enforcement activity in May (click here for last month’s enforcement actions), in this month’s Round-Up we want to highlight some updates that suggest the Enforcement front may continue to...more

Jones Day

CFTC Divisions Interpret "U.S. Person" Definition and U.S. Location Versus Foreign Location

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A 2024 CFTC enforcement action settlement that may have introduced a new test for when the Commodity Exchange Act and the agency's regulations apply on a cross-border basis concerned then-CFTC Commissioner and now Acting CFTC...more

Troutman Pepper Locke

Troutman Pepper Locke Weekly Consumer Financial Services Newsletter – May 2025 # 4

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To keep you informed of recent activities, below are several of the most significant federal and state events that have influenced the Consumer Financial Services industry over the past week....more

Holland & Knight LLP

New Jersey Federal Court Sides with Kalshi Over Prediction Market Contracts

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Prediction market platform Kalshi has secured a preliminary injunction against the New Jersey Division of Gaming Enforcement (the Division), preventing the state from enforcing a cease-and-desist order that aimed to halt...more

Jones Day

CFTC Operating and Enforcement Divisions Issue Advisory on Referrals to Enforcement Division

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On April 17, 2025, the Commodity Futures Trading Commission's ("CFTC") operating divisions ("Divisions") provided guidance in an advisory on the criteria they will use when determining whether to refer self-reported...more

Morgan Lewis

CFTC Staff Issue Advisory on Criteria for Referrals to the Division of Enforcement

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The staff of the US Commodity Futures Trading Commission (CFTC or Commission) on April 17, 2025 issued an advisory outlining the criteria the agency’s Market Participants Division, Division of Clearing and Risk, and Division...more

Husch Blackwell LLP

CFTC Releases Criteria for Operating Divisions to Refer Violations to Enforcement Division

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On April 17, 2025, the Commodity Futures Trading Commission’s (CFTC) Market Participants Division (MPD), the Division of Clearing and Risk (DCR), and the Division of Market Oversight (DMO)—collectively the Operating...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

DLA Piper

Blockchain and Digital Assets News and Trends – April 2025

DLA Piper on

This periodic bulletin is designed to help companies identify important legal developments governing the use and acceptance of blockchain technology, smart contracts, and digital assets. While the use cases for blockchain...more

Skadden, Arps, Slate, Meagher & Flom LLP

CFTC Issues Advisory on Referrals to the Division of Enforcement

On April 17, 2025, three operating divisions of the Commodity Futures Trading Commission (CFTC) jointly issued an advisory to provide guidance on the materiality or other criteria they will use in deciding whether to make a...more

Davis Wright Tremaine LLP

CFTC Eliminates PTMMM Disclosure Requirements for Swap Entities

On April 4, 2025, the CFTC's Division of Market Participants issued No-Action Letter 25-09 regarding the controversial Pre-Trade Mid-Market Mark ("PTMMM") requirements in CFTC Regulation 23.431, effectively eliminating the...more

Katten Muchin Rosenman LLP

After 12 Enforcement Actions and 9 No-Action Letters, CFTC Staff Effectively Repeals the Pre-Trade Mid-Market Mark Disclosure...

The Commodity Futures Trading Commission's (CFTC or Commission) Market Participants Division (MPD) issued Letter 25-09, which effectively eliminates the pre-trade mid-market mark (PTMMM) disclosure requirement for uncleared...more

Cornerstone Research

CME Group Disciplinary Notices Held Steady in 2024 After Significant Jump in 2023

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Disciplinary notices issued by the CME Group’s Market Regulation Enforcement team remained steady in 2024 after experiencing a significant increase in 2023, according to a new report by Cornerstone Research. The report,...more

BakerHostetler

Weekly Blockchain Blog - April 2025

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U.S. Financial Services Firms Announce Digital Asset Initiatives - A major U.S. financial services company and operator of global financial exchanges and clearinghouses recently announced an agreement with the issuer of the...more

Katten Muchin Rosenman LLP

CFTC Withdraws Controversial SEF Registration Staff Letter

The Division of Market Oversight (DMO) of the Commodity Futures Trading Commission (CFTC) has withdrawn its previous staff advisory letter on swap execution facility (SEF) registration requirements (Letter 21-19). ...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

Jones Day

New CFTC Cooperation, Self-Reporting, and Remediation Enforcement Advisory Introduces Major Changes

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The Commodity Futures Trading Commission's ("CFTC") new enforcement advisory introduces several major changes in policy and a matrix helping those facing potential or actual CFTC investigations quantify the extent to which...more

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