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SEC Staff Clarifies That Meme Coins Are Not Securities

The Staff stated that most meme coins are not subject to federal securities laws or SEC fraud enforcement; who will oversee meme coins remains an open question. On February 27, 2025, the Securities and Exchange...more

President Trump Issues Executive Order on Digital Assets

With its pro-crypto stance and urgent posture, the executive order promises to make the US the “crypto capital of the planet.” On January 23, 2025, President Trump issued a highly anticipated executive order on digital...more

CFTC Issues Staff Advisory on the Use of Artificial Intelligence in CFTC-Regulated Markets

As AI use proliferates, the advisory reminds CFTC-regulated entities of their existing obligations and the CFTC’s intention to monitor for ongoing risks. On December 5, 2024, the staff of the Commodity Futures Trading...more

On the Margins: CFTC’s Digital Asset Markets Subcommittee Recommends Expanded Use of Non-Cash Collateral Through Blockchain...

With appropriate safeguards, distributed ledger technology may expand the use of non-cash assets as derivatives collateral, while mitigating certain market infrastructure inefficiencies....more

What’s Next for DAOs in the Wake of the Ooki Decision?

The viability of DAO structures draws attention after a judge declares that a decentralized autonomous organization is a “person” under the law. On June 8, 2023, the US District Court for the Northern District of...more

Regulators Are Setting Sights on Crypto Market Manipulation

Multiple U.S. government agencies have pursued a stream of enforcement actions in the digital asset industry in recent years. In fiscal year 2022, 20% percent of the enforcement actions brought by the Commodity Futures...more

SEC Unveils Strategic Plan With Renewed Focus on Technology

The plan directs the agency to develop a robust regulatory framework to prevent market misconduct, as SEC officials’ public comments keep advancements in technology high on the agenda. On August 25, 2022, the Securities...more

Digital Commodities Consumer Protection Act Seeks to Empower CFTC

The latest bipartisan crypto bill would give the CFTC new tools and authorities to regulate digital commodities, with a focus on market integrity and consumer protection. On August 3, 2022, a bipartisan group of US...more

Responsible Financial Innovation Act Offers Clarity, Safeguards for Digital Assets - SEC and Securities

Securities issues are covered in Title III (Responsible Securities Innovation) of the Responsible Financial Innovation Act (RFIA). The RFIA would add a new Section 41 to the Securities Exchange Act of 1934 (Securities...more

CFTC Issues Request for Information on Climate-Related Financial Risk

The agency will use the information to take further steps to address climate risks in the commodity derivatives markets. On June 2, 2022, the Commodity Futures Trading Commission (CFTC) issued a Request for Information...more

PWG Issues Clarion Call for US Legislation on Stablecoins

The report addresses the market risks and regulatory challenges presented by stablecoins and urges Congress to act quickly. On November 1, 2021, the President’s Working Group on Financial Markets (PWG) in conjunction...more

New US Digital Assets Bill Casts Wide Net

An ambitious proposal could bring digital assets into the mainstream regulatory fold. During an eventful summer for the digital assets industry, it may have been easy to miss US Representative Don Beyer’s introduction of the...more

“SOFR First” Initiative Takes Flight

As the countdown to the LIBOR sunset enters its final six months, the CFTC staff is trying to help the market transition. With less than six months to go before the London Interbank Offered Rate (LIBOR) expires on December...more

El Salvador Christens Bitcoin as Legal Tender

A sovereign nation’s decision to adopt Bitcoin as legal tender raises interesting questions — and legal ramifications. On June 8, 2021, El Salvador’s Legislative Assembly voted to establish Bitcoin as unrestricted legal...more

CFTC Takes Action With New Climate Risk Unit

The CFTC continues to demonstrate a commitment to using its regulatory mandate to combat climate change risks to the US financial system. On March 17, 2021, the Commodity Futures Trading Commission (CFTC) announced the...more

2020 Digital Asset Regulatory Lookback (US Edition)

Regulators once again offered piecemeal guidance, while focusing on risks and enforcement. Meanwhile, innovation and institutional adoption took off. Last year, Latham & Watkins sounded a hopeful note that 2020 would provide...more

Federal Reserve Recognizes Significance of Climate Risks on Financial Stability

The US prudential regulator is paying attention to climate risks, and will likely act to mitigate those risks if they threaten financial stability. In its November 2020 Financial Stability Report (the Report), the Board of...more

CFTC Adds Another Building Block to its Digital Asset Framework

The CFTC issues stringent guidelines for FCMs seeking to custody digital assets in connection with physically delivered futures contracts or swaps. The US Commodity Futures Trading Commission’s (CFTC’s) Division of Swap...more

CFTC Report: Climate Change Threatens Stability of US Financial System

A watershed CFTC report highlights the dangers of climate change to the US economy, and provides a broad risk-mitigation roadmap. On September 9, 2020, the US Commodity Futures Trading Commission’s (CFTC’s) Climate-Related...more

What the CFTC Interpretation of “Actual Delivery” Means for Crypto

The long-awaited guidance clarifies the application of the “actual delivery” exception to leveraged virtual currency transactions with retail purchasers. Earlier this year, the US Commodity Futures Trading Commission...more

COVID-19 Update: CFTC Relief for the Derivatives Market

In the face of pandemic-related disruptions, CFTC staff have relieved exchanges, dealers, intermediaries, and other market participants from certain compliance requirements. Last week, the US Commodity Futures Trading...more

COVID-19 and the Derivatives Markets: What NFA Members Need to Know

The self-regulatory organization responds to the US derivatives market’s shift to remote working arrangements. As the novel coronavirus outbreak (COVID-19) continues to spread across the globe, causing various disruptions,...more

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