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Commodities Futures Trading Commission Corporate Counsel

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 -
Wiley Rein LLP

SEC Is Looking at Your Vendor Contracts for Whistleblower Restraints – Fines Seven More Companies

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The U.S. Securities and Exchange Commission (SEC) recently settled charges against seven companies for violating SEC Rule 21F-17(a), which prohibits conduct that hinders whistleblowing to the SEC. The settlements focus on...more

Holland & Hart LLP

Key Compliance Takeaways for Companies from the DOJ's New Corporate Whistleblower Program

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On August 1, 2024, the U.S. Department of Justice (“DOJ”) announced its new “Corporate Whistleblower Awards Pilot Program” (“DOJ Program”), a three-year initiative managed by DOJ’s Money Laundering and Asset Recovery Section....more

A&O Shearman

CFTC Resolves First Action for Impeding Whistleblowers Over Objections of Two Commissioners

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On June 17, 2024, the Commodity Futures Trading Commission (“CFTC” or “the Commission”) issued a groundbreaking order against an energy, metals, and minerals commodity trading company (the "Company”) registered in Singapore....more

BCLP

CFTC’s Annual Enforcement Results: Another Blockbuster Year

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The Commodity Futures Trading Commission ("CFTC") recently released its enforcement results for Fiscal Year 2023 ("FY 2023"), which ran from October 1, 2022, through September 30, 2023. ...more

Morrison & Foerster LLP

U.S. Sanctions Enforcement: 2023 Trends and Lessons Learned

Today’s alert—the second in our Sanctions 2023 Year in Review Series—provides an overview of U.S. sanctions enforcement in 2023, including the key lessons learned from the public enforcement actions issued by the U.S....more

Morrison & Foerster LLP

Top 10 International Anti-Corruption Developments for December 2023

Designed for busy in-house counsel, compliance professionals, and anti-corruption lawyers, this newsletter summarizes some of the most important international anti-corruption law and enforcement developments from the past...more

Foley & Lardner LLP

A Review of Recent Whistleblower Developments - April 2023

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Whistleblower Developments is a periodic report covering significant cases, decisions, proposals, and legislation related to whistleblower statutes and how they may impact your business. Recent developments include: Third...more

Skadden, Arps, Slate, Meagher & Flom LLP

Court Ruling Could Affect the Future Direction of DAOs

A March 27, 2023, decision by a California federal court in a putative class action, Sarcuni v. bZx DAO, has brought into focus how courts might construe the legal existence of decentralized autonomous organizations (DAOs)....more

Proskauer Rose LLP

SEC Approach In Wahi Presents New Challenges For Crypto

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Government scrutiny of the crypto market has been sharply increasing in recent months on the criminal and civil enforcement fronts. In parallel proceedings that will be seen in other digital asset contexts — as in the...more

K&L Gates LLP

Message Received: SEC Zeros In On Off-Channel Communication

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INTRODUCTION - On 7 February 2023, the U.S. Securities and Exchange Commission (SEC) Division of Examinations (the Division) released its 2023 examination priorities. As expected, the Division’s priorities highlight areas...more

Akin Gump Strauss Hauer & Feld LLP

A Fractured Framework: Regulatory Actions Against Mango Token Trader Highlight Complexities of Crypto Enforcement

Key Points - The recent indictment and multiple regulatory enforcement actions brought against a crypto trader alleged to have committed market manipulation highlight the ongoing fractured oversight of the crypto markets...more

Morgan Lewis - All Things FinReg

Court OKs CFTC’s Service of Process Through Online Forum, Chat Box in Ooki DAO Action

The US District Court for the Northern District of California ruled on December 20, 2022, that the Commodity Futures Trading Commission (CFTC) properly served the defendant, Ooki DAO, by posting summons documents in Ooki...more

Morrison & Foerster LLP

Top 10 International Anti-Corruption Developments for November 2022

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Designed for busy in-house counsel, compliance professionals, and anti-corruption lawyers, this newsletter summarizes some of the most important international anti-corruption law and enforcement developments from the past...more

WilmerHale

FTX Bankruptcy - What Could Be Next for the Industry?

WilmerHale on

One of the world’s largest cryptocurrency exchanges - FTX Trading Ltd. - and many of its affiliates filed for bankruptcy earlier this month. While the full impact of the FTX bankruptcy is not yet clear, various responses from...more

Morrison & Foerster LLP

The Rise of Rule 10b5-1 Enforcement and How Companies Can Mitigate Risk of DOJ and SEC Actions

The U.S. Department of Justice (DOJ) and Securities and Exchange Commission (SEC) have recently intensified their scrutiny of insider trading under Rule 10b5-1 trading plans. The emerging trend of enforcement investigations...more

Davis Wright Tremaine LLP

CFTC’s Annual Enforcement Results Include Notable and Novel Cases

The Commodity Futures Trading Commission ("CFTC") recently released its enforcement results for Fiscal Year 2022 ("FY 2022"). In addition to detailing the recovery of over $2.5 billion in restitution, disgorgement, and civil...more

A&O Shearman

SEC And CFTC Orders Concerning Electronic Communications

A&O Shearman on

On September 27, 2022, the SEC announced charges against affiliates of 11 financial institutions (15 broker-dealers and one investment adviser) for allegedly failing to maintain and preserve electronic communications and...more

Jones Day

A DAO Is No Defense: CFTC Says Decentralization Does Not Immunize DeFi from Regulation

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In Short - The Situation: Under the existing legal regimes, decentralized autonomous organizations ("DAO" or "DAOs") have been viewed as a way to hedge against regulatory action by way of a decentralized structure. The...more

Katten Muchin Rosenman LLP

Holders of DAO Governance Tokens Beware: According to the CFTC, Voting May Be Hazardous to Your Well-Being

Natural persons and legal entities are potentially jointly and severally liable for all of a decentralized autonomous organization's (DAO) violations of the Commodity Exchange Act (CEA) and Commodity Futures Trading...more

Davis Wright Tremaine LLP

CFTC Takes Aim at DAO Members in bZeroX Settlement

The CFTC's recent announcement of its settlement with a decentralized crypto protocol operator and its two individual founders, together with its complaint against the successor protocol, reflects a novel approach to...more

Moore & Van Allen PLLC

Beyond “Security or Commodity”: Different Types of Digital Assets

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In a prior post, we discussed the recent proposed rules from the Securities and Exchange Commission (“SEC”) and Commodity Futures Trading Commission (“CFTC”) regarding certain non-public information reported to the SEC and...more

ArentFox Schiff

First-of-a-Kind Crypto Insider Trading Prosecution: SEC-v-Wahi et al Action May Have Broad Implications Across the Digital Asset...

ArentFox Schiff on

As use of cryptocurrency investment has increased throughout the world, regulators have faced a bevy of novel questions, especially related to applying different strains of law to regulate novel digital assets. To date,...more

Morrison & Foerster LLP

Top 10 International Anti-Corruption Developments for May 2022

Designed for busy in-house counsel, compliance professionals, and anti-corruption lawyers, this newsletter summarizes some of the most important international anti-corruption developments from the past month, with links to...more

Akin Gump Strauss Hauer & Feld LLP

The Responsible Financial Innovation Act – A Bullet Point Summary

Key Points - On June 7, 2022, Senators Cynthia Lummis (R-WY) and Kirsten Gillibrand (D-NY) released long-awaited legislation addressing the regulatory and tax treatment of digital assets. Their Responsible Financial...more

Sheppard Mullin Richter & Hampton LLP

May 2022 Crypto Enforcement Actions and Regulatory Guidance Roundup

In May, we saw a slower month for crypto enforcement actions by state and federal regulators. See our March 2022 Crypto Enforcement Actions Roundup blog here where we discuss the regulatory guidance and jurisdiction of...more

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