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A Signal of Things to Come? New CME Rule 512 Reflects Modified Stance for...
By Athena Eastwood, Gregory Mocek, Jonathan Flynn, Neal Kumar and Mary Treanor. On March 24, 2015, the CME Group, Inc. (“CME”) announced a proposed amendment to Rule 512 indicating that it will impose...
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Supreme Court’s Holding in Oneok v. Learjet Could Lead to New Risks for...
By Joseph Bial, Gregory Lawrence, Gregory Mocek, Paul Pantano, Charles F. (Rick) Rule, Daniel Howley, Thomas Millar, and Natalie Mitchell On April 21, 2015, the Supreme Court decided Oneok v. Learjet,...
View ArticleTariff Compliance Is Not Enough: FERC Imposes Nearly Thirty-Five Million...
By Doron Ezickson, Thomas Millar, and Mary Treanor On May 29, 2015, the Federal Energy Regulatory Commission (“FERC”) issued an Order against Powhatan Energy Fund, LLC and its trading partners, Dr....
View ArticleREMIT: The Road to Enforcement
By Doron Ezickson and Adam Topping Following a number of recent developments, described below, the rules and regulations enacted under the European Union (EU) Regulation on Wholesale Energy Markets...
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”)...
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 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 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...
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SAVE 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 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 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 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 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 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 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 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 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 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 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 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...
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