Earlier this year, the U.S. Department of Justice (“DOJ”) released its highly anticipated Cryptocurrency Enforcement Framework (the “Framework”). The Framework was developed as part of the Attorney General’s Cyber-Digital...more
On March 24, 2020, the U.S. Commodity Futures Trading Commission (the Commission or the CFTC) finalized long-awaited interpretive guidance regarding what constitutes the “actual delivery” of a digital asset in the context of...more
The Commodity Futures Trading Commission proposed to revise its position limits regime by increasing to 25 (from nine) the number of commodity derivatives contracts subject to federal limits; by augmenting the number of...more
Last week, the Commodity Futures Trading Commission publicized a cascade of settlements of enforcement actions alleging breaches of laws and rules related to supervision, spoofing, reporting, and misappropriation of...more
Both the Commodity Futures Trading Commission and the Chicago Board of Trade settled related disciplinary actions for speculative position limits violations. The CFTC sanctioned the trading firm while the CBOT sanctioned the...more
The Department of Justice raised the stakes in spoofing enforcement actions by including racketeering charges in an indictment filed last week alleging spoofing by three traders over many years. The Commodity Futures Trading...more
On September 4, 2019, the Securities and Exchange Commission (“SEC”) and the Commodity Futures Trading Commission (“CFTC”) announced they had entered into settlements with Options Clearing Corporation (“OCC”) regarding its...more
Two food giants agreed to resolve charges brought by the Commodity Futures Trading Commission that they manipulated or attempted to manipulate prices of the Chicago Board of Trade’s December 2011 wheat futures contract and...more
U.S. Developments - Regulatory Developments - CFTC Announces Two Events Designed to Encourage FinTech Innovation - On June 27, 2019, the Commodity Futures Trading Commission (“CFTC”) announced two events designed to...more
The Commodity Futures Trading Commission determined not to stand in the way of a rule amendment by ICE Futures U.S. to impose speed bumps on certain orders entered in two futures contracts traded on the exchange. Two...more
International law firm Sullivan & Worcester LLP acted as fund counsel to Exchange Traded Managers Group (ETFMG) on the launch of the first dry bulk shipping exchange-traded fund, Breakwave Dry Bulk Shipping ETF (NYSE ARCA:...more
The Chicago Mercantile Exchange (CME) and the CBOE Futures Exchange (CFE) on December 1, 2017 self-certified contracts for bitcoin futures products with the U.S. Commodity Futures Trading Commission (CFTC). Additionally, on...more
Regulation - Next on the SEC’s Regulatory Agenda: A Chief Valuation Officer? - First, the SEC required funds to designate a chief compliance officer. Then, the SEC proposed that funds designate a liquidity...more
Here’s a sign of the times, or at least, the changing tenor of banking in America. After years of exclusivity that saw it refusing customers with less than $10 million on hand, Goldman Sachs is opening itself up to common...more
CFTC Announces Proposal to Amend the Definition of "Material Terms" - On September 10, the U.S. Commodity Futures Trading Commission Division announced that it will publish in the Federal Register a proposed amendment to...more
The CFTC recently approved a futures contract on a dividend index as a non-security based index futures contract over the SEC’s objection that the dividend index contract could be a security future; the CFTC’s actions may...more
Broker-Dealer and Two Senior Officers Fined US $2.5 Million for Market Access Violations - Wedbush Securities Inc. and two senior officers resolved an enforcement action previously filed against them during June 2014...more
CFTC Proposes Margin Rules for Uncleared Swaps and Approves Special Treatment for Operations-Related Swaps With Certain Government-Owned Natural Gas and Electric Utilities - A few weeks after the Federal Reserve Bank...more
In this issue: - CFTC Exempts MTFs from US Registration Requirements - CFTC Guidance Relating to Trading on SEFs and DCMs - NFA Issues Notice to Members Regarding Member Obligations Under NFA Bylaw 1101...more