CFTC Approves Supplemental Proposal for Proposed Regulation AT
By: Athena Eastwood, Anthony Mansfield, Paul Pantano, Neal Kumar, Natalie Mitchell and Lamiya Rahman On November 4, 2016, the Commodity Futures Trading Commission (“CFTC” or the “Commission”) approved,...
View ArticleNot Your Grandmother’s Form 40
By Athena Eastwood, Anthony Mansfield, Paul Pantano, Neal Kumar and Natalie Mitchell A common tool that the Commodity Futures Trading Commission (“CFTC” or the “Commission”) relies upon to conduct...
View ArticleSupreme Court Justices Appear Hesitant to Narrow the Scope of Insider Trading...
Since the Second Circuit Court of Appeals’ December 2014 decision in United States v. Newman, the government’s ability to aggressively pursue insider trading cases involving tipping has been in doubt....
View ArticleCFTC Issues Fourth Penalty for Inaccurate Large Trader Reporting of Swaps
On September 27, 2016, the U.S. Commodity Futures Trading Commission (“CFTC” or the “Commission”) issued a fourth penalty for violations of its Swaps Large Trader Reporting (“Swaps LTR”) rule. This...
View ArticleCFTC Staff Issues Final Swap Dealer De Minimis Exception Report
By Athena Eastwood, Anthony Mansfield, Paul Pantano and Neal Kumar On August 15, 2016, Staff of the U.S. Commodity Futures Trading Commission (“CFTC”) published a final report regarding the de minimis...
View ArticleCFTC Issues $560,000 Penalty for Inaccurate Large Trader Reporting of Swaps
By Anthony Mansfield, Jonathan Flynn, Neal Kumar and Michael Selig On July 6, 2016, the Commodity Futures Trading Commission (“CFTC” or the “Commission”) fined Barclays Bank PLC (“Barclays”) $560,000...
View ArticleCFTC Holds Roundtable to Consider Proposed Regulation AT
By Gregory Mocek, Paul Pantano, Neal Kumar, Michael Selig, and Mary Treanor On June 10, 2016, Staff for the Commodity Futures Trading Commission (“CFTC”) held a public roundtable to discuss its...
View ArticleTraders and Compliance Professionals Take Note: Phase One of New BIS “Global...
By Anthony Mansfield, Gregory Mocek, Jonathan Flynn, and Jorge Pesok On May 26, 2016, the Foreign Exchange Working Group (“FXWG”) of the Bank for International Settlements (“BIS”) published the first...
View ArticleCFTC Unanimously Approves Supplemental Proposal on Position Limits
By Anthony Mansfield, Paul Pantano, Jonathan Flynn, Neal Kumar and Michael Selig On May 26, 2016, the Commodity Futures Trading Commission (“CFTC”) unanimously approved a proposed supplement...
View ArticleCFTC Proposes Amendment to RTO-ISO Order
By Athena Eastwood, Mark Haskell, Anthony Mansfield, Gregory Mocek, Paul Pantano, Brett Snyder, Jonathan Flynn, Christopher Hood, Neal Kumar, Thomas Millar, and Michael Selig On May 10, 2016, the...
View ArticleCompliance Departments Must Continue to Evolve as Regulators Refine Their...
By Anthony Mansfield, Gregory Mocek, Paul Pantano and Jonathan Flynn The government’s pursuit of alleged “spoofing” continues to garner headlines with the criminal authorities recently securing a...
View ArticleLong-Awaited Decision is a Mixed Result for Litigants Battling FERC...
By Paul Pantano, Thomas Millar and Mary Treanor Individuals and organizations litigating the imposition of civil penalties by the Federal Energy Regulatory Commission (“FERC” or “Commission”) under its...
View ArticleCFTC Awards More than $10 Million to Whistleblower
On April 4, 2016, the Commodity Futures Trading Commission (“CFTC”) announced a whistleblower award of more than $10 million. This is only the third whistleblower award that the CFTC has approved...
View ArticleCFTC Adopts Final Trade Option Rule
Effective February 23, 2016, ICE Futures U.S., Inc. (“ICE” or “Exchange”) issued a revised Wash Trade Frequently Asked Questions (“ICE FAQ”). This ICE FAQ replaces a 2009 ICE Wash Trade FAQ and...
View ArticleNew ICE Futures U.S. Wash Trade FAQ
Effective February 23, 2016, ICE Futures U.S., Inc. (“ICE” or “Exchange”) issued a revised Wash Trade Frequently Asked Questions (“ICE FAQ”). This ICE FAQ replaces a 2009 ICE Wash Trade FAQ and...
View ArticleSAVE THE DATE: 2016 Spring Energy & Commodities Conference
Cadwalader, Wickersham & Taft LLP will host an in-depth discussion on the evolving regulatory, transactional and business issues facing U.S. and international energy and commodities market...
View ArticleCFTC / CME Settle Misappropriation Case
On December 2, 2015, the U.S. Commodity Futures Trading Commission (“CFTC” or “Commission”) and the New York Mercantile Exchange (“NYMEX”) simultaneously announced settlements with Arya Motazedi, a...
View ArticleNew DOJ Policy Regarding Individual Accountability for Corporate Wrongdoing
On September 9, 2015, the U.S. Department of Justice announced a new policy regarding individual accountability for corporate misconduct. The policy, described in a memo authored by Deputy Attorney...
View ArticleFCA and Ofgem Question Adequacy of Commodity Firms’ Compliance and Market...
By Doron Ezickson and Adam Topping In the most recent edition of its regular market conduct and transaction reporting-focused ‘Market Watch’ publication, the UK Financial Conduct Authority (“FCA”)...
View ArticleCFTC Division of Market Oversight Holds Roundtable to Assess the Made...
By Anthony Mansfield, Paul Pantano, Neal Kumar, Lamiya Rahman and Mary Treanor On Wednesday, July 15, 2015, the Commodity Futures Trading Commission’s (“CFTC”) Division of Market Oversight (“DMO”)...
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