On April 17, 2025, three operating divisions (the “Operating Divisions”) of the U.S. Commodity Futures Trading Commission (“CFTC”) and the Division of Enforcement (“DOE”) provided guidance in CFTC Letter 25-13 (the...more
4/29/2025
/ CFTC ,
Disclosure Requirements ,
Enforcement Actions ,
Financial Crimes ,
Materiality ,
New Guidance ,
Penalties ,
Regulatory Requirements ,
Reporting Requirements ,
Risk Management ,
Self-Reporting
The Advisory sets out factors that the Enforcement Division will use to rate self-reporting and cooperation. This rating places a company or individual within a “tier” used to determine the Mitigation Credit amount available....more
On October 17, 2023, during a speech at the Program on Corporate Compliance and Enforcement held at the New York University School of Law, the Commodity Futures Trading Commission (CFTC) Director of Enforcement, Ian McGinley,...more
Overall cryptocurrency crime levels are down, according to a report from Chainalysis reviewing crypto crime trends, but this past year has still seen certain categories of crypto crime, such as ransomware, continue to...more
On May 24, 2023, Edward A. Imperatore, a partner in Morrison Foerster’s Investigations + White-Collar Defense group and former Assistant U.S. Attorney for the Southern District of New York, moderated a panel, entitled “Market...more
The U.S. Department of Justice (DOJ) and Securities and Exchange Commission (SEC) have recently intensified their scrutiny of insider trading under Rule 10b5-1 trading plans. The emerging trend of enforcement investigations...more
11/9/2022
/ CFTC ,
Chief Technology Officer (CTO) ,
Cooling-Off Rule ,
Corporate Counsel ,
Department of Justice (DOJ) ,
Enforcement Actions ,
Insider Trading ,
MNPI ,
Proposed Amendments ,
Rule 10b-5 ,
Securities and Exchange Commission (SEC)
On August 9, 2022, in CFTC v. EOX Holdings LLC, the first insider trading trial in a Commodity Futures Trading Commission (CFTC) enforcement action, a jury in the U.S. District Court for the Southern District of Texas found...more
On March 16, 2022, Commodity Futures Trading Commission (“CFTC”) Chairman Rostin Behnam delivered a keynote address at the FIA Boca 2022 International Futures Industry Conference. Behnam called for a “culture of compliance”...more