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Sidley Austin LLP | USA | 11 Mar 2019

CFTC Announces Enforcement Advisory for Commodity Exchange Act Violations Involving Foreign Corrupt Practices

On March 6, 2019, at the American Bar Association’s (ABA) National Institute on White Collar Crime, Commodity Futures Trading Commission (CFTC)


Sidley Austin LLP | USA | 13 Feb 2019

NFA Creates New Internal Controls Requirements for CPO Members

Effective April 1, 2019, National Futures Association (NFA) members that are commodity pool operators (CPOs) will be required to implement internal


Sidley Austin LLP | USA | 5 Dec 2018

CFTC Proposes to Overhaul its SEF Rules and Adopts a Permanent Threshold for the Swap Dealer De Minimis Exception

At an open meeting of the Commodity Futures Trading Commission (CFTC) on November 5, 2018, the CFTC Commissioners voted to approve (i) a final rule


Sidley Austin LLP | USA | 3 Dec 2018

U.S. SEC and CFTC Fiscal Year 2018 Whistleblower Reports Chart Dramatic Escalation of Whistleblower Programs

The U.S. Securities and Exchange Commission (SEC) and Commodity Futures Trading Commission(CFTC) Offices of the Whistleblower have issued their


Sidley Austin LLP | USA | 12 Oct 2018

CFTC Chairman Giancarlo's White Paper: Cross-Border Swaps Regulation 2.0

On October 1, 2018, the Chairman of the U.S. Commodity Futures Trading Commission (CFTC) published a long-awaited white paper titled “Cross-Border


Sidley Austin LLP | USA | 23 Aug 2018

CFTC Proposes Rules to Simplify Process for Non-U.S. Clearing Organizations to Obtain DCO Registration Exemption

The Commodity Futures Trading Commission (CFTC) has issued a notice of proposed rulemaking (NPR) proposing to codify the CFTC’s existing policies and


Sidley Austin LLP | USA, Global | 31 Jul 2018

Initial Margin Requirements on the Horizon: FAQs for Buy Side Firms

The regulatory requirements for posting and collecting initial margin (IM) currently apply principally to the uncleared over-the-counter (OTC)


Sidley Austin LLP | USA | 26 Jul 2018

CFTC and CME Fine Market Participant for Attempted Manipulation by Sending “False Signal” to Market

On July 12, the Commodity Futures Trading Commission (CFTC) and the CME Group (CME) both announced settled proceedings against Lansing Trading Group


Sidley Austin LLP | USA | 20 Dec 2017

CFTC Proposes Interpretation of “Actual Delivery” in Connection with Virtual Currency

On December 15, 2017, the Commodity Futures Trading Commission (CFTC or the Commission) issued a proposed interpretation of the term “actual


Sidley Austin LLP | USA | 3 Oct 2017

Proper Supervision by CPOs: Are You Performing Daily Reconciliation on Cash Accounts?

Daily reconciliation may be fairly common for fund managers in relation to trading accounts, but may not always be the standard for cash accounts

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