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Commodities Futures Trading Commission Internal Controls

The United States Commodities Futures Trading Commission was created in 1974 to regulate commodity futures and option markets. The Commission’s mission is to protect market participants and the public from... more +
The United States Commodities Futures Trading Commission was created in 1974 to regulate commodity futures and option markets. The Commission’s mission is to protect market participants and the public from fraud, abuse, and systemic risk associated with derivatives subject to the Commodities Exchange Act. In 2010, as a result of the Frank-Dodd Wall Street Reform and Consumer Protection, the Commission’s role was expanded to include drafting rules for regulating the swaps marketplace. less -
Kohn, Kohn & Colapinto LLP

Whistleblower Awards for Auditors are Key to Meeting OECD Guidelines

According to the Institute of Internal Auditors “Politics of Internal Auditing” (2015), 55% of chief audit executives were directed to commit important findings from their audit reports. 49% of chief audit executives were...more

Eversheds Sutherland (US) LLP

Enforcement appears as messages disappear: The perils of personal and ephemeral messaging

On December 17, 2021, a financial institution agreed to pay $200 million in fines to the Securities and Exchange Commission and Commodities Futures Trading Commission for allowing employees to discuss business on their...more

The Volkov Law Group

OCC Fines JP Morgan Chase $250 Million for Deficient Internal Controls

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Banking regulators have been flexing their muscles.  With the coming Biden Administration, this may portend the beginning of a new, enforcement wave.  Some have suggested that banks are resolving these cases before a more...more

Skadden, Arps, Slate, Meagher & Flom LLP

CFTC Issues New Enforcement Guidance on Cooperation Recognition in Its Orders

On October 29, 2020, the Commodity Futures Trading Commission (CFTC) Division of Enforcement (Division) issued a memorandum (Guidance) providing guidance for Division staff to follow when recommending the recognition of an...more

Cozen O'Connor

CFTC Issues New Guidance Prioritizing Compliance Programs in Enforcement Decisions

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On September 10, 2020, the Commodity Futures Trading Commission (the CFTC) issued a new guidance memorandum outlining factors that the Division of Enforcement (the division) will consider when evaluating compliance programs...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

A&O Shearman

FCPA Digest - Recent Trends and Patterns in the Enforcement of the Foreign Corrupt Practices Act - July 2019

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Recent Trends And Patterns In FCPA Enforcement - Although the DOJ and SEC brought a relatively low number of FCPA enforcement actions in the first half of 2019, an unusually large portion of those enforcement actions...more

Katten Muchin Rosenman LLP

Corporate & Financial Weekly Digest - Volume XIV, Issue 20

SEC/CORPORATE - SEC Proposes Amendments to Update the Accelerated and Large Accelerated Filer Definitions - On May 9, the Securities and Exchange Commission proposed amendments to the accelerated filer and large...more

Akin Gump Strauss Hauer & Feld LLP

NFA Issues Interpretive Notices for CPOs Regarding Internal Controls Systems and Cybersecurity

• The NFA has determined that registered CPOs must implement an internal controls system and highlighted best practices for such a framework. • In response to certain frequently asked questions, the NFA has also updated its...more

Katten Muchin Rosenman LLP

Bridging the Week - December 2018 #2

The Commodity Futures Trading Commission issued a request for input regarding the virtual currency ether. It wants to understand better how bitcoin and ether are different, and any unique qualities of ether (ETH), as it...more

Katten Muchin Rosenman LLP

Corporate & Financial Weekly Digest, Featuring Articles on NFA Compliance Updates for CPOs and Swaps, and Brexit and No-Deal...

BROKER-DEALER - FINRA Issues Report on Examination Findings - This month, the Financial Industry Regulatory Authority (FINRA) issued a report summarizing various findings from recent examinations of its member firms...more

Katten Muchin Rosenman LLP

Bridging the Week - October 2018 #3

The Commodity Futures Trading Commission obtained orders from a federal court in New York concluding its first-filed enforcement action against persons for bitcoin fraud. However, the outcome of an unrelated action having...more

Proskauer - Blockchain and the Law

Cryptoasset Exchanges Respond to New York Attorney General’s Virtual Markets Integrity Initiative

On April 17, 2018, the New York Attorney General’s Office (“OAG”) launched a Virtual Markets Integrity Initiative and sent letters to thirteen cryptoasset trading platforms requesting, through a questionnaire, disclosures on...more

Dorsey & Whitney LLP

This Week In Securities Litigation

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Budget hearings were a focus this week as the Chair of the SEC and Chairman of the CFTC visited Capitol Hill. Both sought substantial increases, requesting more money for technology, inspections and enforcement. While the...more

Manatt, Phelps & Phillips, LLP

Corporate Investigations & White Collar Defense - October 2015

"Wherefore Art Thou Due Process?" Part III - Why it matters: It is time for another installment in our continuing "Wherefore Art Thou Due Process?" coverage into the ongoing constitutional challenges to the SEC's...more

Troutman Pepper

Observation 3.0: Frequently Asked Questions and Answers on the Volcker Rule and the Implications for Foreign Banks Investing in...

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1. Question: What is the Volcker Rule, and when does it take effect? Answer: The Volcker Rule was enacted into law as section 619 of the Dodd-Frank Wall Street Reform and Consumer Protection Act of 2010 (Dodd-Frank...more

Katten Muchin Rosenman LLP

Bridging the Week - August 2015

ESMA Says “No for Now” to Granting Passport Rights to US Fund Managers Under AIFMD: The European Securities and Markets Authority told the European Commission last week that it was premature to grant passport rights to...more

Dorsey & Whitney LLP

This Week In Securities Litigation

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The Second Circuit rejected a petition for rehearing by the U.S. Attorney’s Office in the Newman case. There the Court reversed and dismissed the insider trading actions against two traders based on the failure of the court...more

Dorsey & Whitney LLP

This Week In Securities Litigation

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The Commission announced its largest whistleblower action this week – an award to a person overseas of over $30 million. The agency also filed a series of actions this week....more

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