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CFTC’s Historic Enforcement Action Impacting the Oil Industry & Related Derivatives

The Commodity Futures Trading Commission, under a reconstituted Commission, is signaling a new era of aggressive enforcement of the Commodity Exchange Act. Significant Violations and Penalties - United States- On...more

USD LIBOR Transition: Has the Moving Van Arrived Yet?

According to government regulators across the globe, everyone should have been acting to slow USD LIBOR use for the next six weeks. Except, of course, for the next six weeks… UK FCA Announcement- It is now official –...more

Federal Law to the Rescue?

Snidely Whiplash kidnaps Nell and, in the show’s opening, ties her to the railroad tracks to get even with his nemesis, Dudley Do-Right, of the famed Royal Canadian Mounted Police. Menacing music plays. In each episode,...more

LIBOR Transition Comparison: US vs. UK (Focusing on Interdealer Brokers)

As part of the ongoing transition from the London InterBank Offering Rate (LIBOR) to the Secured Overnight Financing Rate (SOFR) recommended by the Alternative Reference Rates Committee (ARRC) as an alternative rate, an...more

The End of LIBOR: The Twilight Zone™ Edition

The United Kingdom’s Financial Conduct Authority announced the future cessation and loss of representativeness of worldwide LIBOR rates. Potential Detrimental Developments - Recent Events - On Friday, March 5,...more

Recent Swap Manipulation Cases

In recent years, the Commodity Futures Trading Commission (CFTC) filed two actions with facts so shocking the reader is forced to ask, ‘can this be how the industry really functions?’ The Complaints - The most recent...more

CFTC’s First Enforcement Action Against an Exchange (NYMEX) for CEA Violations

On August 4, 2020, the Commodity Futures Trading Commission (the “CFTC”) announced that the Honorable Vernon S. Broderick of the U.S. District Court for the Southern District of New York entered a Consent Order approving a...more

The End of LIBOR: SOFR Updates

Previous Repos - In the last Client Alert, it was reported that the New York Fed recently infused approximately $220 billion into the banking system – $70 billion of overnight repos and $150 billion in term repos....more

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