One year into the Trump administration, it remains difficult to forecast what lies ahead with respect to regulatory and white collar enforcement activity. Perhaps most instructive are recent public statements of officials at...more
1/29/2018
/ Broken Windows ,
CFTC ,
Civil Monetary Penalty ,
Criminal Prosecution ,
Department of Justice (DOJ) ,
Enforcement Actions ,
Foreign Corrupt Practices Act (FCPA) ,
Fraud ,
Material Disclosures ,
Multi-Jurisdictional Litigation ,
Municipal Securities Issuers ,
Omissions ,
Ponzi Scheme ,
Retail Investors ,
Securities and Exchange Commission (SEC) ,
Self-Reporting ,
Trump Administration ,
White Collar Crimes
Upon discovering a potential violation, a company is often faced with the dilemma of whether to self-report the incident to its regulator or attempt to deal with the incident through exclusively internal means. On September...more
On August 7, 2017, the Commodity Futures Trading Commission (CFTC or Commission) announced a settlement for a civil penalty of $600,000 with the Bank of Tokyo Mitsubishi UFJ, Ltd. (BTMU) for alleged spoofing violations, with...more
8/16/2017
/ Appeals ,
CFTC ,
Civil Monetary Penalty ,
Commodities Traders ,
Commodity Exchange Act (CEA) ,
Constitutional Challenges ,
Criminal Prosecution ,
Enforcement Actions ,
Japan ,
Settlement Agreements ,
Spoofing ,
Vagueness
On January 19, 2017, the U.S. Commodity Futures Trading Commission’s Division of Enforcement issued two new enforcement advisories outlining the factors the division will consider in evaluating cooperation in the agency’s...more