News & Analysis as of

Market Manipulation Commodity Exchange Act (CEA) Enforcement Actions

Skadden, Arps, Slate, Meagher & Flom LLP

CFTC To Reorganize Task Forces and End ‘Regulation by Enforcement’

On February 4, 2025, CFTC Acting Chair Caroline D. Pham announced that the agency was reorganizing the Division of Enforcement’s nine task forces “to combat fraud and help victims while ending the practice of regulation by...more

Davis Wright Tremaine LLP

Navigating the Financial Markets Regulatory Landscape: Takeaways After the TOTSA Settlement

In the dynamic world of financial regulation, the Commodity Futures Trading Commission (CFTC) has been actively addressing market manipulation with enforcement actions to ensure market integrity. The CFTC's recent settlement...more

BCLP

CFTC’s Consent Order with Trafigura Trading: When Inaction Becomes Action

BCLP on

On June 17, 2024, the CFTC filed a consent order against Trafigura Trading LLC, requiring the company to pay a $55 million civil monetary penalty and implement remedial measures. The CFTC’s order details three violations of...more

WilmerHale

CFTC Anti-Fraud and Anti-Manipulation Authority: A Focus on Intermediaries

WilmerHale on

The 2010 Dodd-Frank Wall Street Reform and Consumer Protection Act (“Dodd-Frank”), significantly expanded the Commodity Futures Trading Commission’s (“CFTC” or “Commission”) anti-fraud and anti-manipulation statutory...more

Davis Wright Tremaine LLP

CFTC Issues Staff Advisory Letters on DCO Regulation: Prime Brokerage Arrangements and Digital Assets

In May 2023, the Division of Clearing and Risk ("DCR") of the Commodity Futures Trading Commission ("CFTC") issued two Staff Advisory letters addressing areas of regulatory focus related to Derivatives Clearing Organizations...more

Nelson Mullins Riley & Scarborough LLP

U.S. Regulators File Complaints for Digital Asset Market Manipulation and Misappropriation

The U.S. Commodity Futures Trading Commission (CFTC) filed a complaint on Jan. 9, 2023, in the U.S. District Court for the Southern District of New York against Avraham Eisenberg. The U.S. Securities and Exchange Commission...more

Cadwalader, Wickersham & Taft LLP

CFTC and SEC Issue Guidance on Security-Based Swaps and Fraud in OTC Swap Disclosures

On October 21, Commodity Futures Trading Commission (“CFTC”) Commissioner Caroline D. Pham issued a concurring statement to the CFTC’s amended complaint originally filed on April 27, 2022 in the U.S. District Court for the...more

Cadwalader, Wickersham & Taft LLP

CFTC’s Enforcement of Fraudulent and Manipulative Pump-and-Dump Scheme in Crypto Commodities

The Commodity Futures Trading Commission (“CFTC”) has two levels of jurisdiction under the Commodity Exchange Act (“CEA”). First, there is an exclusive (or regulatory) jurisdiction over “derivatives” on “commodities,”...more

Jones Day

JONES DAY TALKS®: CFTC and DOJ Target Derivatives Trading Across Industries

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In an effort to pursue unlawful trading in the derivatives markets, the U.S. Commodity Futures Trading Commission ("CFTC") and U.S. Department of Justice ("DOJ") have in recent years engaged in unprecedented levels of...more

Morgan Lewis - Power & Pipes

CFTC Obtains Another Guilty Plea of Market Manipulation, Makes Criminal Referral

The Commodity Futures Trading Commission (CFTC) announced last week that it has obtained another admission from a trader of violations of the Commodity Exchange Act and CFTC regulations ...more

Carlton Fields

Illinois Federal Court Finds Futures Traders Are Estopped From Avoiding Operating Agreement’s Arbitration Clause Where They Sought...

Carlton Fields on

A federal judge in the Northern District of Illinois ruled that Chicago derivatives firm DV Trading LLC can force three futures traders to arbitrate claims that it is withholding $1.6 million to defray a $5 million regulatory...more

Sheppard Mullin Richter & Hampton LLP

Spoofing Enforcement Intensifies

U.S. regulators, in particular the Commodity Futures Trading Commission (“CFTC”), are intently pursuing market manipulation enforcement. The September 30 end of the 2019 fiscal year brought with it a flurry of press releases...more

UB Greensfelder LLP

The Seventh Amendment Right to Jury for Violations of the Commodity Exchange Act – Part II

UB Greensfelder LLP on

This is the second part of a two-part article discussing a defendant’s Seventh Amendment right to jury in an enforcement action by the Commodity Futures Trading Commission under the Commodity Exchange Act for civil monetary...more

UB Greensfelder LLP

The Seventh Amendment Right to Jury for Violations of the Commodity Exchange Act – Part I

UB Greensfelder LLP on

This is the first of a two-part article discussing a defendant’s Seventh Amendment right to jury in an enforcement action by the Commodity Futures Trading Commission under the Commodity Exchange Act for civil monetary...more

A&O Shearman

CFTC Declines To Appeal Ruling That It Failed To Prove Artificiality In Market Manipulation Action

A&O Shearman on

On February 27, 2019, the Commodity Futures Trading Commission (“CFTC”) announced that it would not appeal a November 2018 decision in U.S. Commodity Futures Trading Commission v. Donald R. Wilson, et al., No. 1:13-cv-07884...more

Jones Day

Commodity Exchange Act: Key Decisions from 2018 and Enforcement Trends to Monitor in 2019

Jones Day on

2018 was an interesting year for market participants subject to the Commodity Exchange Act ("CEA"), with federal appellate courts issuing three noteworthy decisions involving claims under the CEA. The Commodity Futures...more

Skadden, Arps, Slate, Meagher & Flom LLP

Federal District Court Dismisses CFTC Price Manipulation Claims and Resets the Standard of Intent Debate

Few price manipulation cases brought by the Commodity Futures Trading Commission (CFTC) ever go to trial. The CFTC case filed against the trading firm DRW Investments LLC (and its CEO) was the exception to that rule and would...more

Sheppard Mullin Richter & Hampton LLP

CFTC Cryptocurrency Enforcement Receives Further Judicial Support

The Commodity Futures Trading Commission (“CFTC”) obtained an important court win and boost to its regulatory authority over Cryptocurrencies this month. A federal district court in Massachusetts recently issued a decision in...more

Skadden, Arps, Slate, Meagher & Flom LLP

Federal Judge Rules Virtual Currencies Are Commodities Under the Commodity Exchange Act

On March 6, 2018, Judge Jack B. Weinstein of the U.S. District Court for the Eastern District of New York ruled that virtual currencies are commodities under the Commodity Exchange Act (CEA) and therefore subject to the...more

Skadden, Arps, Slate, Meagher & Flom LLP

"Southern District Decision Highlights Challenges for Private Litigants Pursuing Manipulation Claims Under the CEA"

The U.S. District Court in the Southern District of New York recently dismissed a class action lawsuit alleging that Total, S.A., Total Gas & Power North America, Inc., and Total Gas & Power Limited (collectively, “Total”)...more

Moore & Van Allen PLLC

As Agency Enforcement Efforts Mount, CFTC Prohibits Private Lawsuits Against RTOs/ISOs for Market Manipulation

Moore & Van Allen PLLC on

Incidents of alleged fraud and market manipulation in the energy markets increasingly have received the attention of federal agency enforcement efforts, including the Federal Energy Regulatory Commission (FERC) and the...more

Morgan Lewis

The US Government’s Charge Against “Spoofing”

Morgan Lewis on

Asset managers should consider the practical implications of these recent developments. Signaling a new area of criminal and civil securities enforcement, federal regulators are flexing their newly acquired powers under...more

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