News & Analysis as of

Reporting Requirements Commodities Futures Trading Commission Compliance

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

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

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

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

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

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

Skadden, Arps, Slate, Meagher & Flom LLP

CFTC Announces New Enforcement Advisory on Self-Reporting, Cooperation and Remediation

On February 25, 2025, the Division of Enforcement of the Commodity Futures Trading Commission (CFTC or the Commission) issued an advisory to Division staff on how to evaluate self-reporting, cooperation and remediation credit...more

Moore & Van Allen PLLC

The Desk - February Edition

January is at least eight weeks – I’m certain of it. Now that it’s February we know who’s running the CFTC and its different Divisions, for the time being. Acting Chair Pham comes to her position with a long history of...more

Morrison & Foerster LLP

Extended Compliance Date for Recent Form PF Amendments

The new year always marks the start of a busy regulatory filing season for registered investment advisers, including investment advisers that file Form PF (“Form PF Filers”). This year could be especially challenging since,...more

Proskauer Rose LLP

SEC and CFTC Extend Compliance Date for Form PF Amendments

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On January 29, 2025, the Securities and Exchange Commission (“SEC”) and Commodity Futures Trading Commission (together, the “Agencies”) jointly announced that the compliance date for the new Form PF would be extended by three...more

A&O Shearman

President Trump's early days in office signal that pro-crypto reforms are ahead

A&O Shearman on

In the past week, we have seen the possible end to the ‘crypto winter’ in the United States, with the Trump Administration signaling that a range of pro-crypto reforms are ahead. These signals, which will likely develop into...more

Akin Gump Strauss Hauer & Feld LLP

SEC Clears the Way for Crypto Custody

On January 23, 2025, barely 72 hours after the appointment of Mark Uyeda as the Acting Chairman of the U.S. Securities and Exchange Commission, and less than 48 hours after Chairman Uyeda announced that Commissioner Hester...more

BCLP

2024 CFTC Enforcement: Agency Celebrates Record Monetary Relief

BCLP on

On December 4, 2024, the Commodity Futures Trading Commission (“CFTC”) released its enforcement results for Fiscal Year 2024 (“FY 2024”), showcasing record awards of monetary relief totaling more than $17.2 billion....more

Moore & Van Allen PLLC

THE DESK: MVA’s Swaps & Derivatives Newsletter

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Our goal is simple, to provide you key updates and insights that you can quickly digest and easily share with your peers, boss, or anyone else that shares a passion for swaps and derivatives news. We know you have to move...more

Mitratech Holdings, Inc

DOJ Unveils Whistleblower Rewards Program: What Every Business Needs to Know

The Department of Justice has launched the Corporate Whistleblower Awards Pilot Program to fight corporate crime. See how it impacts your organization. The U.S. The Department of Justice (DOJ) has just rolled out the...more

BCLP

CFTC’s Annual Enforcement Results: Another Blockbuster Year

BCLP on

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

American Conference Institute (ACI)

U.K. Parliament Giving Whistleblower Protections a Fresh Review

Recent legislative developments in the United Kingdom, public remarks from the new director of the UK Serious Fraud Office (SFO), and recent parliamentary hearings on the Post Office Horizon scandal put a spotlight on...more

K&L Gates LLP

SEC and CFTC Adopt Amendments to Form PF for Increased Disclosure

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Brief Overview - On 8 February 2024, the US Securities and Exchange Commission (SEC) and the Commodity Futures Trading Commission (CFTC) jointly adopted amendments to Form PF (the Amendments), the confidential reporting form...more

WilmerHale

CFTC Year in Review: 23 Takeaways From 2023 and Predictions for 2024

WilmerHale on

At an industry event in early 2023, Commodity Futures Trading Commission (CFTC or the Commission) Chairman Rostin Behnam set out a comprehensive agenda to include nearly three dozen rulemaking proposals as well as “business...more

Hogan Lovells

Joint SEC-CFTC proposal would overhaul Form PF reporting

Hogan Lovells on

The U.S. Securities and Exchange Commission (SEC) and the Commodity Futures Trading Commission (CFTC) proposed joint amendments to Form PF, a confidential reporting form required of certain SEC-registered investment advisers...more

Akin Gump Strauss Hauer & Feld LLP

CFTC and NFA Year End Regulatory Updates

• Effective January 1, 2020, clarifying amendments to rules regarding communications with the public and use of promotional material will go into effect. • Effective February 1, 2020, CTA will be subject to new limitations...more

Katten Muchin Rosenman LLP

Bridging the Weeks - October 2019

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

Cadwalader, Wickersham & Taft LLP

[Webinar] Not Your Grandmother's Form 40 - Nov. 22nd, 2:00 pm EDT

Tuesday, November 22, 20162:00 PM – 3:00 PM EDT A common tool that the Commodity Futures Trading Commission (“CFTC” or the “Commission”) relies upon to conduct market surveillance, including monitoring compliance with...more

Morrison & Foerster LLP

Setting the Scene - Final SEC guidance on cross-border SBSs is likely to ease concerns surrounding reporting duties and compliance...

On July 13 2016, the US Securities and Exchange Commission (SEC) adopted amendments and guidance (Final Rules and Guidance) related to its rules on the regulatory reporting and public dissemination of security-based swaps...more

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