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Commodities Futures Trading Commission Compliance

The United States Commodities Futures Trading Commission was created in 1974 to regulate commodity futures and option markets. The Commission’s mission is to protect market participants and the public from... more +
The United States Commodities Futures Trading Commission was created in 1974 to regulate commodity futures and option markets. The Commission’s mission is to protect market participants and the public from fraud, abuse, and systemic risk associated with derivatives subject to the Commodities Exchange Act. In 2010, as a result of the Frank-Dodd Wall Street Reform and Consumer Protection, the Commission’s role was expanded to include drafting rules for regulating the swaps marketplace. less -
A&O Shearman

CFTC Releases Guidance On Registered Non-U.S. Swap Entities Using Substituted Compliance

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On May 20, 2025, two divisions within the Commodity Futures Trading Commission (“CFTC”) — the Market Participants Division (“MPD”) and the Enforcement Division (“DOE”) — released procedures providing guidance on how the...more

K&L Gates LLP

NFA Proposes Guidance on Diligent Supervision of Associated Persons

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UPDATE: On 1 May 2025, NFA withdrew Interpretive Notice 9083. The guidance remains available on NFA’s website for industry participants’ review....more

Moore & Van Allen PLLC

The Desk: May Edition

On April 17, 2025, as previewed in the Division of Enforcement’s (“DoE”) February 25, 2025, “Advisory on Self-Reporting, Cooperation, and Remediation”, the Staff of the Market Participants Division (“MPD”) laid the remaining...more

Miles & Stockbridge P.C.

Despite Reduced Enforcement Risks, Businesses Should Invest in Corporate Compliance

Some early actions by the Trump administration have led corporate legal departments to question the extent to which they need to invest in ethics and compliance at this time, based on a perceived reduction in enforcement...more

Davis Wright Tremaine LLP

CFTC Divisions Issue Staff Advisory on Referrals to Division of Enforcement

On April 17, 2025, the Market Participants Division, the Division of Clearing and Risk, and the Division of Market Oversight (collectively, the "Operating Divisions") of the CFTC, along with the Division of Enforcement...more

Cadwalader, Wickersham & Taft LLP

Shifting Signals, April 2025 - Relief for Swap Dealer Pre-Trade Disclosures

On April 4, 2025, the staff of the Commodity Futures Trading Commission ("CFTC") Market Participants Division ("MPD") issued compliance relief for registered swap dealers ("SDs") from the requirement to provide the so-called...more

Cadwalader, Wickersham & Taft LLP

Regulation in Flux, March 2025 - CFTC Staff Withdraws Advisory on Swap Execution Facility Registration Requirement

On March 13, 2025, the Commodities Futures Trading Commission (“CFTC”) issued Letter 25-05, withdrawing controversial and much-criticized Staff Letter 21-19 (“SEF Registration Advisory”), which was issued September 29, 2021...more

Akin Gump Strauss Hauer & Feld LLP

CFTC Acting Chair Caroline D. Pham Announces CFTC’s 30-Day Enforcement Sprint

On February 25, 2025, the U.S. Commodity Futures Trading Commission (CFTC) released an enforcement advisory regarding the impact of self-reporting, cooperation and remediation in enforcement cases (the “Enforcement...more

Husch Blackwell LLP

Acting CFTC Chairman Caroline D. Pham Releases Additional Enforcement Guidance

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On March 11, acting Commodity Futures Trading Commission (CFTC) Chairman Caroline D. Pham offered insight into the regulator’s February 25, 2025 advisory in a keynote addressed delivered at Boca, the annual International...more

Paul Hastings LLP

The CFTC Is “in the Mode to Make Deals” (and Other Updates on the Commission)

Paul Hastings LLP on

Yesterday, Acting CFTC Chairman Caroline Pham created a two-week window to bring “reasonable settlement offers” to the commission. Based on my conversations with her and others, I believe the CFTC is in “deal mode” and is...more

Seward & Kissel LLP

CFTC’s Spring Cleaning: Let's Make a Deal (Quickly)

Seward & Kissel LLP on

The Commodity Futures Trading Commission (CFTC) has a lot on its plate—too many enforcement cases, not enough time, and a limited appetite for dragging out every compliance misstep. So, yesterday, at the International Futures...more

Mayer Brown

CFTC’s Division of Enforcement Issues New Advisory on Self-Reporting, Cooperation and Remediation

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AT A GLANCE - New guidance on self-reporting, cooperation, and remediation was recently released by the Commodity Futures Trading Commission’s Division of Enforcement (CFTC). The CFTC’s advisory includes tiered scales for...more

Cadwalader, Wickersham & Taft LLP

Amid Chaos, Regulatory Change Continues Apace, March 2025 - New CFTC Enforcement Guidance

On February 25th, 2025, the Commodity Futures Trading Commission’s (“CFTC”) Division of Enforcement (“Division”) issued a long-awaited advisory (the “Advisory”) regarding its evaluation of how a company’s or individual’s...more

Jenner & Block

Client Alert: CFTC Issues New Enforcement Advisory Aiming to Incentivize Self-Reporting and Cooperation

Jenner & Block on

On February 25, 2025, the Division of Enforcement (the “Division”) of the Commodity Futures Trading Commission (the “CFTC” or “Commission”) issued an Enforcement Advisory which quantifies the monetary credit that entities can...more

Lowenstein Sandler LLP

Crypto Brief - Lowenstein Crypto Newsletter - March 6, 2025

Lowenstein Crypto advises leading digital asset and cryptocurrency projects, exchanges, and trading firms. Our practice covers regulatory advice, transactions and structuring advice, investigations, and adversarial matters...more

Carey Olsen

The rise and growth of decentralised digital governance structures – ushering in a new era of finance

Carey Olsen on

The world of finance has been turned on its head. Digital Assets and distributed ledger technology, once the realm of tech enthusiasts, are now capturing the attention of institutional investors. We are witnessing a profound...more

Bracewell LLP

The CFTC’s New Advisory on Self-Reporting, Cooperation and Remediation

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In an advisory announced February 25, 2025, the Division of Enforcement of the Commodity Futures Trading Commission (CFTC or Commission) announced a new regime for assessing cooperation credit in determining fines in the...more

Nelson Mullins Riley & Scarborough LLP

“Free your mind!” — Understanding the CFTC’s New Mitigation Credit Matrix

The Commodity Futures Trading Commission (CFTC) recently issued a significant Enforcement Advisory detailing how companies and individuals can earn Mitigation Credit....more

Husch Blackwell LLP

CFTC Enforcement Division Releases Mitigation Credit Matrix for Self-Reporting, Cooperation, and Remediation

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On February 25, 2025, the Commodity Futures Trading Commission (CFTC) signaled a shift in its enforcement approach by releasing new guidance on the role self-reporting and cooperation play in its assessment of penalties. The...more

Alston & Bird

Enter the Matrix: CFTC’s New Framework for Self-Reporting, Cooperation, and Remediation

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Our White Collar, Government & Internal Investigations Group analyzes new enforcement guidance from the Commodity Futures Trading Commission (CFTC) that aims to incentivize self-reporting of potential violations....more

Baker Botts L.L.P.

CFTC Issues Enforcement Advisory Adopting New Approach for Consideration of Self-Reporting, Cooperation, and Remediation

Baker Botts L.L.P. on

On February 25th, the Commodity Futures Trading Commission (CFTC or Commission) adopted a new approach for how the Division of Enforcement (Division) will assess self-reporting, cooperation, and remediation efforts when...more

Morrison & Foerster LLP

New CFTC Advisory Incentivizes Self-Reporting, Cooperation, and Remediation

The Advisory sets out factors that the Enforcement Division will use to rate self-reporting and cooperation. This rating places a company or individual within a “tier” used to determine the Mitigation Credit amount available....more

A&O Shearman

Carbon fraud is on the rise—but so is the regulatory counteroffensive

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At COP29 in Baku, new rules were adopted for carbon markets under Article 6 of the Paris Agreement. These rules are meant to increase the transparency of the country-to-country trading of carbon credits under Article 6.2....more

Paul Hastings LLP

The Financial Innovation and Technology for the 21st Century Act: A Template for Future Crypto Market Legislation?

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Last year, the House passed the Financial Innovation and Technology for the 21st Century Act (FIT 21) to close gaps created by current laws that did not anticipate the emergence of digital assets. FIT 21 seeks to divide...more

Fenwick & West LLP

The Legal Landscape for DAOs: Key Lessons from Lido DAO and Ooki DAO

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As is the case with much of the blockchain industry, decentralized autonomous organizations (DAOs) are unique. The existence of a DAO does not necessarily imply the existence of a legal entity or an intent to share profits....more

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