On December 5, 2024, the Staff of every market-facing division of the U.S. Commodity Futures Trading Commission (CFTC) issued a joint “Staff Advisory” on the use of artificial intelligence in CFTC-regulated markets and...more
On September 12, 2024, the Commodity Futures Trading Commission (CFTC) finalized the first major changes to CFTC Regulation 4.7 (Rule 4.7) in over 30 years. Among other technical revisions, the amendments to Rule 4.7,...more
While it took a few decades to surface, the fact pattern set forth in the movie “Trading Places” has finally come to pass. However, instead of the alleged wrongdoers bribing a U.S. government official for a sneak peek at...more
Starting on January 1, 2024, entities that are organized in the United States or are registered to do business in the United States will generally be required to disclose to the Financial Crimes Enforcement Network (an...more
12/11/2023
/ Beneficial Owner ,
CFTC ,
Commodity Trading Advisors (CTAs) ,
Corporate Transparency Act ,
FinCEN ,
Foreign Entities ,
Fund Managers ,
Investment Management ,
Private Funds ,
Securities and Exchange Commission (SEC) ,
Venture Capital
Key Points -
Last week, the SEC announced settlements with 10 broker-dealers and affiliated investment advisers in connection with their failures to maintain and preserve electronic “off-channel” communications....more
On March 29, 2023, the National Futures Association (NFA) announced that NFA Compliance Rule 2‑51: Requirements for Members and Associates Engaged in Activities Involving Digital Asset Commodities will become effective on May...more
INTRODUCTION -
Registered investment advisers to private funds clients are required to make filings with the Securities and Exchange Commission (SEC) each year and deliver certain information to their clients. In...more
Key Points -
Until August 12, 2025, CPOs and CTAs may continue to file position limit disaggregation notices upon request, rather than prospectively, and exempt CTAs may continue to rely upon the “independent account...more
Key Points -
The DOJ and CFTC have filed insider trading charges against a Houston-based energy trader for allegedly disclosing confidential information to a third party who then used the information to trade profitably....more
Compliance Reminders for 2022 -
Registered investment advisers to private funds clients are required to make filings with the Securities and Exchange Commission (SEC) each year and deliver certain information to their...more
Key Points -
Beginning as early as September 2, 2021, a “branch office” for NFA purposes will exclude any remote working location not held out to the public as a CPO or CTA office where one or more APs from the same...more
Key Point -
As of September 30, 2021, private fund managers registered with the CFTC as CPOs or CTAs will be required, under new NFA guidance, to supervise certain third-parties performing regulatory functions....more