Keith Ross on HFT, Reg NMS and Dark Pools
The Law Commission, a U.K. body which makes suggestions for legislative reform, has published a call for evidence on the operation of English private international law (conflicts of law rules) in relation to digital assets...more
The Law Commission for England and Wales recently published “Digital assets and ETDs in private international law: which court, which law? Call for evidence” ("Call for Evidence"). At the same time, it also published a short...more
London, UK - Sullivan & Worcester (Sullivan) is advising Arqit Limited (Arqit), a leader in quantum-safe encryption, in relation to its documentary framework to support the creation, issue and storage of electronic promissory...more
London, UK – Partner Geoffrey Wynne at Sullivan & Worcester (Sullivan) has assisted the International Trade & Forfaiting Association (ITFA) in relation to an important update to its Digital Negotiable Instruments (DNI)...more
Today is the day, the Electronic Trade Documents Act (ETDA) is now in force! Although a short piece of legislation, it is flexible and seeks to give certain trade-related electronic documents the same legal recognition as...more
Blockchain analysis is a powerful tool that provides insight into what is happening on a blockchain network. Who is trading with whom? Which wallets are most active on decentralized finance exchanges? Which wallets are...more
Following the highly anticipated publication by the Law Commission of its Electronic Trade Documents Report and draft Electronic Trade Documents Bill on 16 March 2022, the Electronic Trade Documents Bill (the Bill) is now on...more
A New York intermediate appellate court has held that an insured was entitled to coverage under its fidelity bond for over $141 million in losses it sustained after an independent broker used the insured’s electronic trading...more
The Commodity Futures Trading Commission (“CFTC” or “Commission”) sanctioned Blockratize, Inc. d/b/a Polymarket.com on January 3, 2022 and ordered it to pay a $1.4 million civil money penalty for violations of the Commodity...more
The SEC’s enforcement action with a leading seller of market data (App Annie Inc.) signals its concern with misleading data use representations. While the data at issue was not “personally identifiable” information, but...more
At the latest Trade & Export Finance webinar, Geoff Wynne, head of the Trade & Export Finance Group and Sullivan's London office, gave a whistle-stop tour of recent developments in digital options available in trade finance,...more
Big Friday win for Apple in its ongoing battle with Epic Games, as N.D. Cal. Federal Judge Yvonne Gonzalez Rogers ruled that Cook & Co. didn’t “need to reinstate the popular video game Fortnite in its App Store,” a blow to...more
Eight months after firing its CEO, Steve Easterbrook, for “sexting with a subordinate,” McDonald’s has sued Easterbrook for allegedly “lying, concealing evidence and fraud” in what appears to be a series of other workplace...more
- The Commodity Futures Trading Commission (CFTC) formally withdrew its highly controversial “Regulation Automated Trading” (Reg AT). - In its place, the CFTC proposed principles-based rules applicable to designated...more
The US Commodity Futures Trading Commission (CFTC) on June 25 withdrew from consideration Regulation Automated Trading (Reg AT), along with its comprehensive registration and “AT Person” designation regime, and instead...more
The U.S. Department of Labor issued a Field Assistance Bulletin on June 24, 2020, announcing that it will not routinely assess pre-litigation liquidated damages as part of the settlement process for claims under the Fair...more
On June 25, 2020, the Commodity Futures Trading Commission (CFTC or Commission) held an open meeting and voted unanimously to approve a final rule prohibiting post-trade name give-up for swaps executed anonymously on a swap...more
The New York Stock Exchange announced today that it will activate its Business Continuity Plan, temporarily closing its equities and options (Amer and Arca) trading floors....more
The Securities and Exchange Commission has solicited the views of exchanges, broker-dealers and investors on a range of questions related to market data since at least 1999 when it published SEC Concept Release: Regulation of...more
Several major downstream companies have recently embarked upon large-scale digital transformations with anticipated capital spend tallying in the tens to hundreds of millions of dollars. While these initiatives promise...more
Guidance of questionable legal accuracy from the European Securities and Markets Authority (ESMA) casts doubt on the ability of non-EU members of EU exchanges to provide client access to such exchanges through a technique...more
The Hong Kong Securities and Futures Commission (“SFC”) has issued a paper containing proposals to introduce cyber security guidelines under the Securities and Futures Ordinance (the “SFO”) applicable to internet brokers (the...more
On Wednesday, the Federal Circuit, in a per curiam order, denied SHzoom's motion to make the Trading Technologies opinion precedential. The order of course gave no reasons for the decision. Nonetheless, the underlying...more
CFTC Postpones Swap Dealer Compliance Date for OTC Swaps Variation Margin Requirements; Other Regulators Likely to Exercise Forbearance: On February 13, the Commodity Futures Trading Commission’s Division of Swap Dealer and...more
Regulation AT – An Update - From the time Regulation AT was initially proposed by the CFTC over a year ago, the CFTC has solicited and considered numerous comment letters, held a public roundtable, supplemented the...more