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Enforcement Actions Financial Institutions Commodities Futures Trading Commission

Moore & Van Allen PLLC

The Desk: July Edition

We hope everyone has a relaxing, safe, and enjoyable Fourth of July. Despite some personnel changes at the CFTC, the current administration seems to be hitting its stride in terms of enforcement actions and regulatory...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

Katten Muchin Rosenman LLP

Financial Markets and Funds Quick Take | Issue 38

Katten's Financial Markets and Funds Quick Take is a monthly newsletter highlighting key noteworthy developments potentially affecting financial markets and funds....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

Moore & Van Allen PLLC

The Desk: April Edition

March is over and all of our brackets are busted. We hope you have been enjoying, Moore & Van Allen’s very own, Jay Bilas’ coverage on ESPN. In this month’s newsletter we will walk you through the CFTC’s continued updates on...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

WilmerHale

2024 CFTC Year in Review: An Overview of a Transitional Year

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Coming off a busy 2024, we expect that 2025 will be a landmark year for the Commodity Futures Trading Commission (CFTC or Commission). Rostin Behnam’s resignation as Chairman on January 20 marked the end of the Biden...more

A&O Shearman

Implications of the SEC’s stance that meme coins are not securities

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On February 27, 2025, the U.S. Securities and Exchange Commission’s Division of Corporation Finance issued a formal Staff Statement on “meme coins.” In this statement, the SEC staff took the position that typical meme...more

Moore & Van Allen PLLC

The Desk: March Edition

In other news from last month, we found out that Brian Quintenz was nominated by President Trump to serve as the next CFTC Chair. See our synopsis on Quintenz below. If and when Quintenz is confirmed—TBD on when the Senate...more

Morrison & Foerster LLP

FinReg Currents - Week 4

On February 7, 2025, newly confirmed Office of Management and Budget (OMB) director Russell Vought replaced Treasury Secretary Scott Bessent as acting director of the CFPB....more

Paul Hastings LLP

A New Administration: Major Immediate Shifts in the Digital Asset Regulatory Landscape

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This week’s Crypto Policy Tracker highlights major developments, including a crypto executive order from the new Trump administration and the launch of a new SEC Crypto Task Force led by Commissioner Hester Peirce, signaling...more

Sullivan & Worcester

SEC and CFTC Continue Their Lucrative Pursuits of Penalizing Unapproved Communication Methods

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SEC's and CFTC's Enforcement Actions Against Multiple Firms - In its continued pursuit of rooting out and penalizing broker-dealers and investment advisers for their failure to prevent unapproved communication methods, the...more

White & Case LLP

The Shadow Financial System

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The concept of the shadow financial system rose to international prominence in the aftermath of the 9/11 terrorist attacks. In an interview with a Pakistani newspaper a month later, Osama bin Laden stated that Al Qaeda were...more

Thomas Fox - Compliance Evangelist

Messaging App Compliance in Regulated Industries: Lessons from Recent Enforcement Actions

In recent years, regulated industries, particularly broker dealer firms like Wells Fargo and Morgan Stanley, have faced increased scrutiny from regulatory bodies due to their lack of compliance in policing messaging apps. The...more

Troutman Pepper Locke

Troutman Pepper Weekly Consumer Financial Services Newsletter - September 2023 # 2

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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 Finance Services industry over the past week...more

Zuckerman Spaeder LLP

Off-Channel Communication Risks: SEC and CFTC Enforcement Actions and Compliance Considerations for Financial Firms

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In an increasingly digital world, financial firms need to be mindful of the variety of electronic communication channels that their employees use for work. Even where firms require employees to use firm-managed email networks...more

BCLP

A Time of Transition for the CFTC

BCLP on

Over the past year, the Commodity Futures Trading Commission continued moving its focus away from practices like spoofing, instead bringing high-profile actions in the crypto space and reaching significant settlements with...more

Cadwalader, Wickersham & Taft LLP

SVB and Signature Bank Resolution – CFTC-Related Implications

Many of the transactions involving qualified financial contracts (“QFC”) with Silicon Valley Bank (“SVB”) and Signature Bank constitute Commodity Futures Trading Commission (“CFTC”) jurisdictional transactions that may be...more

K&L Gates LLP

Message Received: SEC Zeros In On Off-Channel Communication

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INTRODUCTION - On 7 February 2023, the U.S. Securities and Exchange Commission (SEC) Division of Examinations (the Division) released its 2023 examination priorities. As expected, the Division’s priorities highlight areas...more

A&O Shearman

CFTC Releases Its Annual Enforcement Results

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On October 20, 2022, the Commodity Futures Trading Commission (“CFTC”) released its enforcement results for Fiscal Year (“FY”) 2022, reporting that it had filed 82 enforcement actions.  Eighteen of the actions brought in FY...more

Goodwin

SEC and CFTC Send Powerful Message With $2 Billion in Fines Related to Social Media and Text Recordkeeping Lapses

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​​​​​​​The SEC and CFTC recently charged 11 large financial institutions and their affiliates for failing to collect, monitor, and preserve communications over WhatsApp and other messaging services. These settlements follow a...more

Robinson & Cole LLP

With $1.1 Billion Penalty Deal, SEC Joins DOJ in Firing Warning Shot at Financial Services Industry About Outdated Employee...

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Last week, the United States Securities and Exchange Commission (SEC) fined 16 Wall Street firms a total of $1.1 billion for recordkeeping violations based on the failure to maintain employees’ electronic communications, such...more

Cadwalader, Wickersham & Taft LLP

Eleven Financial Institutions Pay $700 Million to Settle Recordkeeping and Supervision Violations Related to Off-Channel Business...

On September 27, the Commodity Futures Trading Commission (“CFTC”) issued orders to settle charges against 11 major U.S. and international financial institutions and their swap dealer (“SD”) and futures commission merchant...more

Goodwin

CFTC Commissioner Romero Calls on Agency to Bring the “HEAT” in Enforcement Actions

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CFTC Commissioner Christy Goldsmith Romero recently criticized the agency’s longstanding practice of settling enforcement cases without seeking admissions of wrongdoing (so-called “no-admit/no-deny” settlements). She suggests...more

BakerHostetler

Financial and Crypto Firms Explore Integration; NFT Market Expands; FATF/Basel Publish Crypto Guidance; DOJ/CFTC Bring Crypto...

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Financial Firm Launches Crypto Group, MakerDAO Votes to Integrate with Bank - A major multinational financial institution recently “announced the formation of its Digital Assets and Financial Markets group.” According to...more

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