On June 25, 2020, the five commissioners of the Commodity Futures Trading Commission (CFTC), by a vote of three-to-two, withdrew proposed Regulation Automated Trading (Reg. AT), and by a vote
Continue Reading CFTC Cancels and Replaces Proposed Regulation AT
On Oct. 11, 2019, the Financial Crimes Enforcement Network (FinCEN), the U.S. Commodity Futures Trading Commission (CFTC), and the U.S. Securities and Exchange Commission (SEC), published a Joint Statement on
Continue Reading CFTC, FinCEN and SEC Issue Joint Statement Reminding Persons in Digital Assets Space of Obligations Under Bank Secrecy Act
Departing from its historical practice but following the approach taken by the SEC and FINRA, the Commodity Futures Trading Commission (CFTC) on Feb. 12, 2019, announced its first release of
Continue Reading CFTC and NFA Commodities Regulatory Update
The CFTC has asserted that Bitcoin is, and other virtual currencies may be, commodities under the Commodity Exchange Act. As such, pursuant to Section 2(c)(2)(D) of such Act, “off exchange”
Continue Reading Financing Bitcoin: The Problem of Actual Delivery
The rise of blockchain technology ventures raising money preternaturally through initial coin offerings and token generation events (collectively, ICOs) is a capital formation disruptor, one which has and will continue
Continue Reading Regulators Weigh in on Digital Assets, Tokens, Securities, and Derivative Instruments Used in ICOs
Shareholders Carl A. Fornaris and William B. Mack of global law firm Greenberg Traurig, LLP will be participating at the Financial Markets Association’s 2017 Treasury and Capital Markets Legal and
Continue Reading Greenberg Traurig’s Carl Fornaris and William Mack Participate at FMA’s Legal and Legislative Issues Conference
On Sept. 25, 2017, the Program on Corporate Compliance and Enforcement and the Institute for Corporate Governance and Finance at New York University School of Law hosted a policy speech
Continue Reading Details on the CFTC’s New Self-Reporting Policy
Yesterday, the U.S. Commodity Futures Trading Commission’s (CFTC) Division of Swap Dealer and Intermediary Oversight (DSIO) announced the issuance of a time-limited no-action letter stating that, from March 1, 2017
Continue Reading No Action Relief Regarding Variation Margin Rules