Bridging the Week – March 2019 #2 | Katten Muchin Rosenman LLP

Unexpectedly, the Commodity Futures Trading Commission introduced a brand new initiative to encourage non-registrants to self-report overseas corrupt practices, which it claimed may additionally represent violations of legal guidelines and guidelines it administers. Non-registrants who flip themselves in, cooperate with the CFTC and remediate their violations will profit from a presumption that the CFTC’s Division of Enforcement will ordinarily advocate no high quality to the Commission – though it seems possible their conditions shall be referred to different regulation enforcement businesses for consideration. Separately, the National Futures Association formally proposed bylaw and rule amendments, in addition to a brand new Interpretive Notice, geared toward making swaps related individuals smarter about swaps markets and relevant laws. As a outcome, the following issues are coated on this week’s version of Bridging the Week:

  • New CFTC Initiative Encourages Non-Registrants to Self-Report Foreign Corrupt Practices (contains Legal Weeds);
  • NFA Seeks Smarter Swaps APs Through New Training Requirements (contains Compliance Weeds); 
  • CME Group Warns of Greater Scrutiny for EFRPs With Off-Market Prices (contains Compliance Weeds); and extra.

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Article Version

Briefly:

  • New CFTC Initiative Encourages Non-Registrants to Self-Report Foreign Corrupt Practices: James McDonald, Director of Enforcement of the Commodity Futures Trading Commission, introduced a brand new initiative geared toward encouraging non-CFTC registrants to voluntarily self-report violations of the Commodity Exchange Act – the precept regulation overseen by the CFTC – involving overseas corrupt practices.

According to a particular Enforcement Advisory, for non-registrants who self-report such violations, absolutely cooperate with the CFTC, and remediate their violations, the Division of Enforcement will really useful to the Commission a decision of their wrongdoing “with no civil penalty, absent aggravating circumstances involving the nature of the offender or the seriousness of the offense.”

Mr. McDonald introduced the new coverage in a speech at the American Bar Association’s National Institute on White Collar Crime. According to the DOE director, acts constituting overseas corrupt practices can also implicate CFTC-administered legal guidelines prohibiting fraud, manipulation, false reporting or different offenses. He indicated that the CFTC works carefully with the Securities and Exchange Commission and the Department of Justice to make sure that investigations into such issues are “properly coordinated.” Mr. McDonald commented that, to the extent the CFTC brings an enforcement motion as a part of such coordinated exercise, the CFTC will be sure that any high quality it requires “appropriately accounts” for any high quality by one other enforcement physique, and if the CFTC insists on disgorgement or restitution, it can give greenback-for-greenback credit score for disgorgement or restitution mandated in different associated enforcement actions.

It shouldn’t be clear what prompted Mr. McDonald’s announcement right now. However, he indicated that the CFTC at the moment has “open investigations” associated to how corrupt practices in any variety of kinds may impression commodity markets’ costs.

The Foreign Corrupt Practices Act, enacted in 1977 – three years after the authorization of the CFTC in 1974 – makes it unlawful for sure individuals and entities to make funds to overseas authorities officers to assist acquire or retain enterprise. (Click here for normal background on the FCPA in a information revealed by the Securities and Exchange Commission and the Department of Justice.)

In November 2016, JPMorgan Chase agreed to settle civil expenses introduced by the SEC and the Board of Governors of the Federal Reserve System that, between 2006 and 2013, it offered jobs and internships to relations and pals of Asia-based authorities officers, together with Chinese authorities officers, to retain or acquire funding banking enterprise. The SEC stated this conduct violated the FCPA. (Click here for particulars in the article“Bank Settles SEC and FRB Charges That It Violated Federal Law by Hiring Relatives and Friends of Asia-Based Government Officials” in the August 23, 2015 version of Bridging the Week.)

Similarly, in August 2015, The Bank of New York Mellon Corporation agreed to pay sanctions of virtually US $15 million to resolve allegations by the SEC that its retention of three interns throughout 2010 and 2011 constituted violations of the FCPA’s anti-bribery and inner accounting management provisions. The SEC claimed that, in order to keep up and increase enterprise with an unidentified Middle Eastern sovereign wealth fund, BNY agreed to retain three members of the family of two authorities officers who had been each senior officers affiliated with the sovereign wealth fund. None of the interns, claimed the SEC, met the “rigorous criteria” of the internship program ordinarily administered by BNY. (Click here for extra info in the article “Student Internships Result in Bank’s Settlement With SEC Over Alleged FCPA Violations” in the August 23, 2015 version of Bridging the Week.)

Legal Weeds: In January 2017, the CFTC’s DOE up to date a 2007 advisory (click on here to entry) to make clear the kind of cooperation it will think about to advocate lowered expenses or sanctions in opposition to an organization or a person in reference to an enforcement investigation or motion. In normal, the Division stated it can look “for more than ordinary cooperation or mere compliance with the requirements of law.” In evaluating this, the Division famous three components it will think about: (1) whether or not the cooperation resulted in “material assistance” to the Commission’s investigation and enforcement motion, together with its success, contemplating the timeliness, nature and high quality of the cooperation; (2) whether or not the cooperation inspired “high quality” help from different individuals contemplating the significance and hurt of the related kind of misconduct and CFTC sources conserved on account of the assist; and (3) the topic’s culpability, and in the case of an organization, its tradition and different related components. (Click here for extra background in the article “Cooperate and Maybe Benefit Says CFTC Division of Enforcement” in the January 29, 2017 version of Bridging the Week.)

Later in the identical yr, Mr. McDonald stated that potential wrongdoers who voluntarily self-report their violations, absolutely cooperate in any subsequent CFTC investigation, and repair the reason behind their wrongdoing to stop a reoccurrence will obtain “substantial benefits” in the type of considerably lesser sanctions in any enforcement continuing and “in truly extraordinary circumstances,” no prosecution in any respect. (Click here for background in the article “New Math: Come Forward + Come Clean + Remediate = Substantial Settlement Benefits Says CFTC Enforcement Chief” in the October 1, 2017 version of Bridging the Week.) Contemporaneously together with his speech, the CFTC’s DOE launched a proper Updated Advisory on Self Reporting and Full Cooperation that memorialized and expanded the parts of Mr. McDonald’s presentation (click on here to entry).

Last yr, the CFTC decided to not carry an enforcement motion in any respect in opposition to Deutsche Bank after the Commission introduced and settled expenses in opposition to a dealer for the financial institution for purportedly mismarking his swap trading portfolio to disguise trading losses. The CFTC stated it decided to not carry an enforcement motion in opposition to Deutsche Bank in reference to this matter due to its “timely, voluntary self-disclosure” of the incident, full cooperation, and “proactive remediation efforts.” (Click here for extra in the article ”Ex-Bank Trader Fined US $350,000 and Banned From All CFTC Overseen Markets for Allegedly Concealing Swaps Trading Losses; Bank That Self-Reported, Cooperated and Remediated Receives Letter Closing Investigation” in the November 11, 2018 version of Bridging the Week.)

The present initiative introduced by the CFTC to encourage self-reporting of FCPA-associated violations seems to be an extension of the company’s prior efforts to encourage self-reporting of different violations of relevant regulation and CFTC guidelines. I shall be curious to see if an enforcement motion is introduced imminently that sheds gentle on the surprising timing of this announcement and initiative.

  • NFA Seeks Smarter Swaps APs Through New Training Requirements: The National Futures Association proposed an amended bylaw and rule, in addition to a brand new Interpretive Notice, requiring that every one related individuals of futures fee retailers, introducing brokers, commodity pool operators and commodity trading advisors appearing as swaps corporations, in addition to individuals designated as APs at swap sellers and main swap members, to fulfill sure minimal proficiency necessities associated to swaps. (Persons appearing as APs of swaps sellers and MSPs should not required to be registered as such.) 

Under NFA’s proposed new guidelines, starting February 1, 2021, all present and new APs at swaps agency intermediaries or individuals designated as APs at swap sellers should fulfill both a “Long Track” or “Short Track” proficiency requirement relying on their job operate. The proficiency necessities will check people’ swaps market data in addition to familiarity with regulatory necessities.

Persons designated as APs in a swap supplier’s sale and trading areas who negotiate, price and/or execute swaps with counterparties and/or are liable for managing the swap supplier’s swaps-associated dangers should fulfill Long Track necessities, as should individuals designated as APs who supervise such individuals. Other individuals at swap sellers designated as APs in addition to individuals designated as APs who’re their supervisors, and swap APs and their supervisors at swaps agency intermediaries, could fulfill both the Long or Short Track necessities.

Since there aren’t any registration necessities for individuals designated as APs at swap sellers, such entities should preserve information that proof related people have well timed glad requisite proficiency necessities. An individual won’t be authorized as a swap AP of a swaps agency middleman except NFA receives proof he/she has well timed taken and handed a proficiency requirement. An particular person who has glad a swaps proficiency requirement whereas at one agency shouldn’t be required to re-fulfill such requirement after he/she joins a brand new swaps agency middleman or swap supplier, offered that the begin date happens inside two years after the final date of employment at the prior agency and his/her new function does not require Long Track proficiency and he/she solely has Short Track proficiency.

Individuals appearing as APs of swap sellers exterior the United States who solely settle for or solicit swaps with non-US counterparties or non-US department workplaces of US swap sellers should not have to fulfill NFA’s new proficiency necessities.

NFA anticipates posting subject material subjects on its Long and Short Track proficiency necessities in addition to related often requested questions on its web site. 

Often, the NFA’s proposed proficiency necessities don’t handle individuals designated as APs at MSPs; it is because NFA doesn’t at the moment have any MSP members. However, based on an NFA official, if essential in the future, the proficiency necessities could be amended to be parallel for individuals designated as APs at MSPs as for individuals designated as APs at swap sellers.

Compliance Weeds: All CFTC-registered APs and any pure individual registered as an FCM, IB, CPO, CTA, flooring dealer or flooring dealer are required to obtain ethics coaching on a periodic foundation, as wanted. Registered entities should have written procedures that describe the frequency and type of coaching. The frequency and kind needs to be based mostly on the measurement and kind of a agency’s enterprise. One measurement shouldn’t be anticipated to suit all. Topics to be addressed ought to embrace an summary of relevant legal guidelines and CFTC guidelines, in addition to related guidelines of relevant self-regulatory organizations that oversee the agency; the registrant’s obligation to watch simply and equitable rules of commerce; learn how to act actually and pretty with due care in the curiosity of shoppers and for the integrity of the market; learn how to preserve an efficient supervisory system and inner controls; learn how to assess the monetary circumstance and funding expertise of shoppers; disclosure of fabric info to clients; and avoidance and disclosure of conflicts of pursuits, amongst different subjects. (Click here for added info in the CFTC’s 2001 Statement of Acceptable Practices With Respect to Ethics Training and here for NFA Compliance Rule 2 -9: Ethics Training Requirements.)

  • CME Group Warns of Greater Scrutiny for EFRPs With Off-Market Prices: CME Group proposed amendments to its Market Regulation Advisory Notice associated to Exchange for Related Positions that clarify that off-market costs for EFRPs should be for reliable functions and usually tend to be topic to regulatory scrutiny. Generally, EFRPs could also be transacted at ”such commercially affordable costs” as agreed by the events, offered such costs conform to the relevant futures or possibility price increments.

The amended MRAN additionally provides a brand new Q/A to make clear that third-celebration techniques accessible to a number of events that permit for digital matching or digital acceptance of bids or affords for EFRPs are prohibited. However, events could use communication applied sciences to bilaterally request EFRP quotes from a number of members and to facilitate privately negotiated EFRPs.

CME Group’s revised MRAN is scheduled to be efficient March 19.

Compliance Weeds: All EFRP transactions should contain the bona fide switch of the money commodity underlying the change contract, or a by-product, associated product or an over-the-counter instrument. A liquidation of the associated place that happens concurrently or shut-in-time with out the events incurring market danger will possible trigger the EFRP to be deemed a prohibited transitory EFRP. 

CME Group will even regard an EFRP as transitory if two EFRPs involving economically equal futures positions traded on a CME Group and one other change lead to the associated place element being offset between the identical events. Structuring a swap in order that it settles by way of an Exchange for Risk Transaction shouldn’t be thought-about to be getting into right into a transitory EFRP, offered the settlement worth (floating price) is topic to materials market danger. Immediately offsetting change of futures for bodily positions involving overseas currency positions should not thought-about transitory EFRPs if executed in accordance with CME Group rule. Click here to entry CME Group Rule 538.Ok; click on here for the at the moment in place EFRP MRAN Q/A 26.) ICE Futures U.S. has equal prohibitions, though it additionally permits instantly offsetting EFP transactions involving bodily supply obligations by members in the London Gold Auction administered by the ICE Benchmark Administration. (Click here to entry ICE Futures U.S. FAQs – November 20, 2017, Q/A22.

Although EFRPs could also be carried out between totally different trading items inside one company group and even inside one firm, they should be for items beneath impartial management and to not switch positions from one trading operation to a different.

More Briefly:

  • Broker-Dealer Fined US $2 Million by FINRA for Purported Five-Year Reg SHO and Supervision Breakdowns: Cantor Fitzgerald & Co. – a Securities and Exchange Commission-registered dealer-supplier – agreed to pay a high quality of US $2 million to the Financial Industry Regulatory Authority to settle allegations that, from January 2013 by way of a minimum of December 2017, it purportedly didn’t adjust to sure elements of the SEC’s Regulation SHO, and didn’t have and observe written supervisory procedures fairly designed to detect such failures. FINRA claimed that the agency’s reliance predominately on handbook brief sale compliance techniques was unreasonable on condition that its trading exercise greater than doubled from 35 billion shares in 2013 to 79 billion shares in 2014. In its investigation, FINRA discovered that Cantor failed to shut out “fail-to-deliver” brief sale positions in a well timed method; in reference to fail-to-ship securities, didn’t borrow first or organize to borrow securities earlier than executing new brief sale orders; failed to offer discover to different dealer-sellers of brief sale trades that had been in violation of relevant regulation; and didn’t supervise brief gross sales trades to satisfy relevant necessities. Moreover, stated FINRA, the agency didn’t act on purple flags of related failures recognized by its compliance personnel. In addition to the financial high quality, Cantor agreed to retain an impartial marketing consultant to finish a overview of the agency’s brief gross sales insurance policies, techniques and coaching associated to Reg SHO. Cantor agreed to the FINRA settlement with out admitting or denying any findings. (Click here for background relating to Reg SHO in an SEC publication Key Points About Regulation SHO.)
  • CFTC Chairman Praises Markets as Best Evaluator of Technology-Driven Innovation: In a speech earlier than the Fourth Annual DC Blockchain Summit, J. Christopher Giancarlo, Chairman of the Commodity Futures Trading Commission, indicated that the CFTC has taken affirmative steps to rework right into a “21st century regulator and craft a contemporary regulatory method.” Critical to this evolution, he stated, had been 4 parts: (1) adopting an “exponential growth mindset” which he stated was marked by anticipating the speedy tempo of change or, colloquially, “skating where the puck is headed”; (2) forming a fintech stakeholder (i.e., LabCFTC); (3) turning into a quantitative regulator partaking in “robust” knowledge assortment and evaluation; and (4) welcoming market-based options. He stated a contemporary regulatory method was essential due to the present exponential technological progress, disintermediation of conventional enterprise fashions and heightened want for technological literacy. Mr. Giancarlo indicated that markets are “the best determinate of the value of technology-driven innovation.” He defended, for instance, the CFTC’s allowance for the self-certification of bitcoin futures contracts at the finish of 2017, arguing that “risk transfer markets comprised of sophisticated institutional investors were in the best place to make individual determinations regarding the value of Bitcoin and the need to offset price or volatility risk.”

In different authorized and regulatory issues involving cryptoassets:

  • Consumers Confused by Cryptoassets According to UK FCA Commissioned Research: The UK Financial Conduct Authority revealed two surveys of customers carried out by third events to discover shopper data of and motivation to buy and use cryptoassets. According to the analysis, the majority of contacted customers entered the cryptoasset market with out doing any analysis. As a outcome, most surveyed customers didn’t perceive digital currency. Some believed that cryptocurrency cash had been tangible property due to references to “mining” and “coin.” The analysis indicated that when customers invested in cryptoassets they predominantly did so to get wealthy rapidly or to not miss out on one thing. However, the survey reported that solely Three % of customers truly purchased cryptoassets. As a results of these surveys, FCA said that it believes that it might have overestimated the “scale of harm” cryptoassets could pose to customers.
  • Leader of Alleged Worldwide Cryptocurrency Pyramid Scheme Arrested in Los Angeles: Konstantin Ignatov, the purported ringleader of an alleged world, fraudulent cryptocurrency enterprise based mostly in Sophia, Bulgaria – OneCoin Ltd. – was arrested in Los Angeles contemporaneously with the unsealing of an indictment in opposition to him and Ruja Ignatova, his sister, each from Bulgaria, and Mark Scott, a resident of Florida. According to the indictments, Mr. Ignatov and Ms. Ignatova helped assist the firm and coordinated advertising and marketing of its purportedly faux cryptocurrency, OneCoin. The firm sought new buyers by way of operation of a pyramid scheme the place member-buyers had been compensated for signing up new member-buyers, claimed the indictments. However, charged the indictments, OneCoin by no means existed as a digital currency on any public and verifiable blockchain and the multi-stage advertising and marketing operation run by the firm was fraudulent. The firm allegedly generated € 3.353 billion (roughly US $3.765 billion) from the fourth quarter of 2014 by way of the third quarter of 2016. Mr. Scott, together with Ms. Ignatova, helped to launder the proceeds of the alleged pyramid scheme, claimed the indictments. The indictments had been filed in a federal court docket in New York City.
  • Justice Department Asks CFTC to Hold Off Discovery in Cryptocurrency Purported Fraud Case Pending Resolution of Parallel Criminal Action: The Department of Justice filed a movement in a federal court docket in Massachusetts to delay discovery in the CFTC’s civil case in opposition to defendants, Randall Carter, Mark Gillespie, and My Big Coin, Inc. for allegedly partaking in a fraudulent digital currency scheme till DOJ’s prison case in opposition to Mr. Carter based mostly on the identical important details is resolved. According to DOJ, the keep is warranted as a result of the civil and prison instances share nearly an identical details and it’s in the public’s finest curiosity to delay the civil trial in order that the defendant can’t “abuse civil discovery to circumvent the criminal rules.” According to DOJ, the events in the CFTC motion didn’t oppose the company’s request. (Click here for particulars in the article “Purported Cryptocurrency Fraudster Indicted for Fraud; Previously Sued by CFTC” in the March 3, 2019 version of Bridging the Week.) 
  • NYMEX and COMEX Permanently Bans 12 Nonmembers From All CME Group Exchanges’ Access for Multiple Trading Offenses and Non-Participation in Disciplinary Processes: Fourteen nonmembers had been sanctioned by the Commodity Exchange, Inc. and the New York Mercantile Exchange for partaking in several trading violations resembling prearranged, prenegotiated and noncompetitive trades; wash trades; TAG50 ID violations; and spoofing-kind conduct. All had been additionally charged with not collaborating in change disciplinary actions. All however two of the respondents had been completely barred from any CME Group change trading whereas 4 of the respondents had been additionally fined from US $50,000 to US $200,000. The respondents had been Kai Kai Hu, Zhuang Lirui, Miao Liu, Ma Qiang, Sharp Link Developments LTD., Jeong Hye Soo, Lim Young Sun, Daguo Wang, Liu Wang, Yu Yang, Cheng Zenglin, Qi Zhaomin, Cui Zhiming, and Chengdao Zhou. 

Separately, FCT Strategy Trading Limited settled expenses introduced by the Chicago Mercantile Exchange that, from January 2015 to July 2015, the agency’s merchants entered unfold futures orders on Globex for Lean Hogs, Feeder Cattle and Live Cattle previous to market opening with the intent to establish the depth of the order e-book and to not enter into bona fide transactions. CME claimed that, on account of these non bona fide transactions, fluctuations in the publicly displayed Indicative Opening Price occurred. Furthermore, CME alleged that FCT, a nonmember, didn’t sufficiently practice or supervise its merchants to stop the prohibited trading scheme. FCT agreed to a high quality of US $75,000 to resolve this matter and carried out remedial measures and coaching following this episode. FCT neither admitted nor denied the expenses.

Alan Fraczek additionally resolved CME expenses for getting into and cancelling orders for Live Cattle, Lean Hog and Feeder Cattle unfold markets on the Globex digital trading platform throughout the pre-opening interval between May 1, 2017, and December 8, 2017, for non bona fide functions. CME claimed that these prohibited orders – additionally purportedly positioned to evaluate depth of market – resulted in fluctuations in the publicly displayed Indicative Opening Price. Mr. Fraczek, who was a nonmember too, was fined US $20,000 and suspended for ten enterprise days from all CME Group trading exchanges.

Element Capital Management LLC settled expenses with the Chicago Board of Trade by submitting to a high quality of US $15,000 and a disgorgement of US $86,365 for a place limit violation. According to CBOT, at the finish of the trading day on August 9, 2018, the agency was 141 contracts over the single and all month limit of 8,000 contracts for 2018 Soybean Oil futures contracts The subsequent trading day, not realizing its mistake, ECM elevated its place leading to a complete of 294 contracts over the required limit. CBOT said that the agency instantly eradicated the overage after realizing its mistake, reaching a revenue of $86,365. ECM neither admitted nor denied the expenses.

  • National Security Agency Gives Away FreeCybersecurity Tools to Help Analyze Malicious Code and Malware: The National Security Agency is offering at no cost reverse engineering instruments to help cybersecurity professionals analyze malicious code and software resembling viruses. Named “Ghidra,” the assortment of NSA open supply software instruments is designed to raised allow cybersecurity professionals to grasp how recognized malware works and what harm it could possibly do.
  • Exchange Sues SEC Over Non-Response to Freedom of Information Act Request: The New York Stock Exchange filed a grievance in opposition to the Securities and Exchange Commission in a federal court docket in the District of Columbia to pressure the SEC to adjust to the change’s request for paperwork associated to the SEC’s dedication in August 2018 that charges set by two nationwide securities exchanges for depth of e-book market knowledge weren’t “fair and reasonable” and “not unreasonable discriminatory,” as required beneath relevant regulation; one other SEC dedication in October 2018 that challenged over 40o exchanges’ rule adjustments as improper limitations or prohibitions of entry; and sure different enumerated proceedings (collectively, “Market Data Proceedings”). (Click here for the SEC order associated to actions taken by NYSE Arca, Inc. and Nasdaq Stock Market LLC; click on here for the SEC order for a overview of actions taken by varied nationwide securities exchanges of their function as registered securities info processors.) The change initially made a request beneath the Freedom of Information Act on November 19, 2018, for paperwork associated to the involvement of Brett Redfearn, Director of the Division of Trading and Markets, in the SEC’s Market Data Proceedings, together with info associated to his recusal or potential recusal from the proceedings, in addition to conferences between the SEC and Mr. Redman and The Wall Street Journal. (According to his LinkedIn web site, previous to becoming a member of the SEC in November 2017, Mr. Redman was Head of Market Structure, Global Markets, at JP Morgan (click on here for particulars).) The Exchange claimed the SEC unlawfully delayed its response past time intervals permitted by regulation which, beneath regulation, is tantamount to a rejection of the change’s request.

Follow-up:

  • Not Just Spoofing, Not Just CME Group Exchanges and ICE Futures U.S.: Two Weeks in the past in the Compliance Weeds part addendum to the article, “Government Argues New Trial for Convicted Spoofer Not Justified by Data Available Before Trial End” (click on here to entry) I famous that, “…market participants must pay equal attention to exchanges’ prohibition against persons entering or causing the entry of order messages with the intent to disrupt or with reckless disregard for the consequences of such messages on the orderly trading of a market” and never simply on prohibitions in opposition to spoofing. In the February 24, 2019 article, I referenced guidelines of CME Group exchanges and ICE Futures U.S. in assist of my advice. However, one not-talked about-change thought it will be good if I made clear that my reference to only two exchanges’ prohibitions was not a suggestion that different exchanges haven’t got the identical kind of prohibitions. They do! (See, for instance, ICE Futures Europe Rule E 2.2(a)(xiv): “No Member (or other person subject to the Regulations) shall in relation to Contracts or Corresponding Contracts entered into, or orders placed, on the Market or otherwise in accordance with the Regulations:- … enter an order or market message or cause an order or market message to be entered with reckless disregard for the adverse impact of the order or market message.”)

For additional info

Broker-Dealer Fined US $2 Million by FINRA for Purported Five-Year Reg SHO and Supervision Breakdowns
http://www.finra.org/sites/default/files/Cantor_AWC_030519.pdf

CFTC Chairman Delighted by DLT’s Digital Trinity’s Effect on Markets:
https://cftc.gov/PressRoom/SpeechesTestimony/opagiancarlo66

CME Group Warns of Greater Scrutiny for EFRPs With Off-Market Prices:
https://www.cmegroup.com/content/dam/cmegroup/notices/market-regulation/2019/03/CME-Group-RA1901-5.pdf

Consumers Confused by Cryptoassets According to UK FCA Commissioned Research:
https://www.fca.org.uk/publication/research/cryptoassets-ownership-attitudes-uk-consumer-survey-research-report.pdf
https://www.fca.org.uk/publication/research/how-and-why-consumers-buy-cryptoassets.pdf

Exchange Sues SEC Over Non-Response to Freedom of Information Act Request:
/ckfinder/userfiles/files/NYSE%20v%20SEC%20Complaint%203-7-19.pdf

Justice Department Asks CFTC to Hold Off Discovery in Cryptocurrency Purported Fraud Case Pending Resolution of Parallel Criminal Action:
/ckfinder/userfiles/files/My%20Big%20Coin%20Pay%20Unopposed%20Motion%20for%20Leave%20to%20Intervene.pdf

Leader of Alleged Worldwide Cryptocurrency Pyramid Scheme Arrested in Los Angeles:

National Security Agency Gives Away FreeCybersecurity Tools to Help Analyze Malicious Code and Malware:
https://www.nsa.gov/resources/everyone/ghidra/

New CFTC Initiative Encourages Non-Registrants to Self-Report Foreign Corrupt Practices:

NFA Seeks Smarter Swaps APs Through New Training Requirements:
https://www.nfa.futures.org/news/PDF/CFTC/InterpNotcNFABylaw301CR2-24ProficiencyRequirementsSwapAPs.pdf

NYMEX and COMEX Permanently Bans 12 Nonmembers From All CME Group Exchanges’ Access for Multiple Trading Offenses and Non-Participation in Disciplinary Processes:

CBOT:

CME:

COMEX and NYMEX:

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