Enforcement Round-Up -
With the longest government shutdown on record taking up nearly half of the month and Acting Chair Pham waiting to pass the baton to Mike Selig (who is quickly progressing through the confirmation...more
12/1/2025
/ CFTC ,
Civil Monetary Penalty ,
Commodity Exchange Act (CEA) ,
Commodity Pool ,
Derivatives ,
Enforcement Actions ,
Fraud ,
IOSCO ,
New Guidance ,
No-Action Letters ,
Swaps
On November 3, 2025, IOSCO released its anticipated Pre-Hedging Final Report (“Final Report”) detailing its assessment of current pre-hedging market practices and setting out recommended guidance for International...more
In keeping with the theme of things during the U.S. government shutdown, this month’s edition of The Desk does not follow our traditional order. Instead of launching into our Enforcement Round-Up first, we begin with the...more
Happy October, the CFTC kept us very busy in September. Nonetheless, it’s time to plan your Halloween costume (unless like me, your children have already decided that for you). Options are Ghost of PTMMM (roams the halls...more
10/1/2025
/ Business Conduct Standards ,
CFTC ,
Commodity Exchange Act (CEA) ,
Derivatives ,
Dodd-Frank ,
Enforcement Actions ,
Government Shutdown ,
Proposed Rules ,
Regulatory Requirements ,
Reporting Requirements ,
Rulemaking Process ,
Self-Reporting ,
Swap Dealers ,
Swaps
We hope everyone has a relaxing, safe, and enjoyable Fourth of July. Despite some personnel changes at the CFTC, the current administration seems to be hitting its stride in terms of enforcement actions and regulatory...more