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”
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CFTC
Regulators Weigh in on Digital Assets, Tokens, Securities, and Derivative Instruments Used in ICOs
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…
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Greenberg Traurig’s Carl Fornaris and William Mack Participate at FMA’s Legal and Legislative Issues Conference
By Greenberg Traurig on
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…
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Details on the CFTC’s New Self-Reporting Policy
By Jeffry M. Henderson & William Mack on
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
…
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New Bill Introduced in the U.S. Senate to Require the Disclosure of Ultimate Beneficial Owners of Corporations and LLCs Formed or Registered in the United States
On August 2, 2017, United States Senators Marco Rubio (R-FL) and Ron Wyden (D-OR) jointly introduced Senate Bill 1717, entitled the “Corporate Transparency Act of 2017” (the “Act”). The Act…
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President Trump to Nominate CFTC Acting Head J. Christopher Giancarlo
By Nanette Aguirre on
Posted in Commodities, Dodd-Frank
President Trump has announced his intention to nominate Commodity Futures Trading Commission (CFTC) acting head J. Christopher Giancarlo as permanent chairman. This news is of high importance for the alternative…
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No Action Relief Regarding Variation Margin Rules
By Nanette Aguirre on
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…
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The US Attorney, CFTC, and Navinder Sarao
We have previously provided updates1 on the Navinder Singh Sarao case, pending in the U.S. District Court for the Northern District of Illinois. After being charged in February 2015…
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Coscia Gets 3 Years in Prison: The Criminalization of Trading Commodities?
By Harris L. Kay & Gregory K. Lawrence on
Sarao, Coscia, and now the Berkshire Power Company, each charged with crimes – spoofing, fraud, false information – relating to commodity trading. Commodity traders likely have incorporated into their compliance…
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FinCEN Finalizes Customer Due Diligence Rule
By Greenberg Traurig on
May 6, 2016, the Financial Crimes Enforcement Network of the U.S. Department of the Treasury (FinCEN) finalized regulations that will require banks, securities broker dealers, mutual funds, futures commission merchants,…
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