Kalshi is a CFTC registered exchange that allows for the placing of cash bets on a variety of real-world events. Specifically, through what it calls “event contracts,” Kalshi allows users to buy positions on whether an event...more
As we have previously noted, the Commodity Futures Trading Commission (CFTC) continues to face legal challenges to its regulatory approach to political event contracts. The past two weeks have seen a flurry of activity in the...more
On July 31, 2024, nine Democratic lawmakers from the House and Senate wrote a letter to the Commodity Futures Trading Commission’s (“CFTC”) Chairman in support of the proposed guidance regarding the listing of voluntary...more
The Commodity Futures Trading Commission ("CFTC") recently proposed new and modified conflicts of interest, fitness, and governance regulations for swap execution facilities ("SEFs") and designated contract markets ("DCMs")....more
Editor's Note The following newsletter provides a roundup summarizing enforcement actions, guidance, rulemakings, and other public statements taken by a federal and/or state financial services regulatory agency, specifically...more
Seeking to ensure that designated contract markets (DCMs) and swap execution facilities (SEFs) adequately incorporate an independent perspective, the Commodity Futures Trading Commission (CFTC) has proposed new rules and...more
During 2023 the Commodity Futures Trading Commission (CFTC) engaged in several regulatory actions aimed at further clarifying its jurisdictional reach over environmental commodity markets generally and the voluntary carbon...more
In Short - The Background: As voluntary carbon credits ("VCCs") have grown in popularity, questions about their integrity and quality have arisen for investors and among regulators and lawmakers. For this reason, many have...more
On September 22, the U.S. Commodity Futures Trading Commission (the “CFTC” or the “Commission”) issued an order disapproving the listing and trading of congressional control event contracts by KalshiEX, LLC (the “Kalshi...more
The Commodity Futures Trading Commission (CFTC) recently issued an order disapproving the listing of a political event contract self-certified by a designated contract market (DCM). This was a long-awaited decision in an...more
On September 7, 2023, the Commodity Futures Trading Commission (CFTC) announced the settlement of three separate enforcement actions in the decentralized finance (DeFi) space: namely, concerning the Opyn protocol and its...more
The Commodity Futures Trading Commision (CFTC) is seeking to increase enforcement in the carbon market and is turning towards its highly successful whistleblower program to aid in the effort. In June 2023, the agency both...more
In March 2023, Commodity Futures Trading Commission (“CFTC”) Chairman Rostin Behnam laid out his regulatory agenda. Among the topics Chair Behnam addressed, several of the thematic areas directly impact the expectations for...more
On April 12, 2023, Tradeweb’s Swap Execution Facility, TW SEF LLC, filed a self-certification for certain overnight index swaps (OIS) referencing USD Secured Overnight Financing Rate (“SOFR”) or GBP Sterling Overnight Index...more
In response to changes in business practices, regulations and laws eventually change, too. During the past few years derivatives markets are witnessing this change as it applies to trading facilities as well as to entities...more
The Securities and Exchange Commission (SEC) and the Commodity Futures Trading Commission (CFTC) recently announced enforcement actions that reflected sweeping, and previously unarticulated, views of their respective...more
On September 22, the Commodity Futures Trading Commission (“CFTC”) asserted its jurisdiction over a decentralized autonomous organization (“DAO”) and its founders, signaling for the industry that even an unincorporated...more
Accurate and timely reporting of swap data is the cornerstone of swap regulation. The CFTC had promulgated its swap reporting rules in 2012, and were after 2012 among the first rules implementing the Dodd-Frank Act to...more
The Commodity Futures Trading Commission (“CFTC” or “Commission”) sanctioned Blockratize, Inc. d/b/a Polymarket.com on January 3, 2022 and ordered it to pay a $1.4 million civil money penalty for violations of the Commodity...more
On January 3, 2022, the Commodity Futures Trading Commission (CFTC) announced an order against and settlement with Polymarket, a blockchain-enabled prediction market that allows users to “bet” on the occurrence of certain...more
As previously discussed, there are quite a few regulatory schemes surrounding Digital Assets and Cryptocurrencies. In addition to the FinCen Rulings, each State has its own regulations. The Internal Revenue Service (“IRS”)...more
On December 8, the CFTC approved a number of final rules, including (i) amendments requiring designated contract markets (DCMs) to implement certain risk controls relating to market disruptions caused by electronic trading,...more
The Commodity Futures Trading Commission (CFTC) has unanimously approved amendments to the real-time swap reporting rules in Part 43 of the CFTC’s regulations by, among other things, clarifying the applicability of the rules...more
- The Commodity Futures Trading Commission (CFTC) formally withdrew its highly controversial “Regulation Automated Trading” (Reg AT). - In its place, the CFTC proposed principles-based rules applicable to designated...more
The US Commodity Futures Trading Commission (CFTC) on June 25 withdrew from consideration Regulation Automated Trading (Reg AT), along with its comprehensive registration and “AT Person” designation regime, and instead...more