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CFTC Divisions Interpret "U.S. Person" Definition and U.S. Location Versus Foreign Location

A 2024 CFTC enforcement action settlement that may have introduced a new test for when the Commodity Exchange Act and the agency's regulations apply on a cross-border basis concerned then-CFTC Commissioner and now Acting CFTC...more

CFTC Operating and Enforcement Divisions Issue Advisory on Referrals to Enforcement Division

On April 17, 2025, the Commodity Futures Trading Commission's ("CFTC") operating divisions ("Divisions") provided guidance in an advisory on the criteria they will use when determining whether to refer self-reported...more

The CFTC is Off to a Fast Start Under Acting Chairman Pham

In a break from the typical acting agency chairman, Acting Commodity Futures Trading Commission ("CFTC") Chairman Caroline Pham has taken several significant actions, signaled several more, and set the agency on a path to...more

New CFTC Cooperation, Self-Reporting, and Remediation Enforcement Advisory Introduces Major Changes

The Commodity Futures Trading Commission's ("CFTC") new enforcement advisory introduces several major changes in policy and a matrix helping those facing potential or actual CFTC investigations quantify the extent to which...more

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