The Securities and Exchange Commission today approved an amendment to the National Market System Plan governing the Consolidated Audit Trail (“CAT”) and provided exemptive relief from certain requirements of Rule 17a-1 under the Securities Exchange Act…
Broker DealerAll Firms
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Broker DealerAll Firms
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FintechCrypto Exchange
The Securities and Exchange Commission today proposed amendments to Exchange Act Rule 15c2-11, which sets out certain information gathering and review requirements for broker-dealers that publish quotations for, or maintain a continuous quoted market in…
The SEC is proposing amendments to Exchange Act Rule 15c2-11, which governs broker-dealer quotation requirements in OTC markets outside national securities exchanges, aiming to update information review standards for enhanced investor protection. This matters for compliance professionals as it could impose stricter due diligence on broker-dealers quoting OTC securities, building on 2020 amendments amid ongoing fixed income implementation challenges, potentially reducing fraud in retail-heavy OTC markets. https://www.sec.gov/newsroom/press-releases/2026-28-sec-proposes-amendments-exchange-act-rule-15c2-11
What Changed
Rule 15c2-11 requires broker-dealers to review current, publicly available issuer information (e.g., via EDGAR or issuer websites) before publishing or submitting quotations for OTC securities, with exceptions like piggybacking limited to scenarios with one-way priced quotes, post-trading suspension restrictions (60 days), and time-bound quoting for shell companies (18 months).
What You Need To Do
- Review processes
- Exception compliance
- Systems updates
- Issuer coordination
- Comment submission
Key Dates
TBD (post-Federal Register publication) - Proposed comment period closes; SEC seeks input on amendments. (Inferred from "consultation" type; exact date not in summary.) https://www.sec.gov/newsroom/press-releases/2026-28-sec-proposes-amendments-exchange-act-rule-15c2-11
Compliance Impact
Urgency: High – Builds on enforced 2020/2021 changes with fixed income phases expired (Phase 3 active since 2024), pressuring broker-dealers on ongoing quotes amid SEC scrutiny; proposals could tighten "publicly available" standards or exceptions, risking enforcement for non-compliant OTC activity in fraud-prone markets. Matters as OTC is retail-dominated, amplifying gatekeeper liability; operational overhauls needed now to avoid quoting halts.
Broker DealerAll Firms
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Broker DealerCrypto Exchange
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The CFTC has issued an Advanced Notice of Proposed Rulemaking (ANPRM) seeking public comments on potential amendments or new regulations for event contracts in prediction markets, focusing on statutory compliance, public interest prohibitions, and cost-benefit analysis. This matters for compliance professionals as it signals heightened CFTC scrutiny and forthcoming rules that could reshape prediction market operations, amid jurisdictional disputes and enforcement priorities. (https://www.cftc.gov/PressRoom/PressReleases/9194-26)
What Changed
This ANPRM proposes no immediate changes, as it is an early-stage consultation seeking input on:
Application of Commodity Exchange Act (CEA) core principles and existing CFTC regulations to prediction markets.
Criteria for prohibiting event contracts deemed contrary to the public interest (e.g., potentially sports, politics, or sensitive topics like government employee outcomes).
Cost-benefit analyses for regulating prediction markets.
It builds on prior actions, including withdrawal of a 2024 proposed ban on certain event contracts and a 2025 staff advisory on sports-related contracts,...
What You Need To Do
- Submit comments
- Review compliance programs
- Monitor developments
Key Dates
April 26, 2026 - Deadline for public comments (45 days after Federal Register publication; ANPRM published March 12, 2026). Comments via CFTC Public Comments Portal. (https://www.cftc.gov/PressRoom/PressReleases/9194-26) DEADLINE
Compliance Impact
Urgency: High - This ANPRM initiates rulemaking that could prohibit certain event contracts or impose new CEA compliance burdens, amid CFTC Enforcement Division advisories on misconduct (e.g., MNPI, manipulation) and jurisdictional defenses against states/SEC. Firms risk enforcement actions if unprepared, especially as prediction markets grow with institutional interest; proactive commenting and program reviews are essential to influence outcomes and mitigate risks.
Broker DealerCrypto ExchangeAll Firms
The two agencies have entered into a MOU to guide coordination and collaboration to support lawful innovation, uphold market integrity, and ensure investor and customer protection.
Broker DealerCrypto Exchange
No description available.
Broker DealerFintechCrypto Exchange
FINRA publishes Notices to provide firms with timely information on a variety of issues. To obtain a Notice published prior to 1995, please contact FINRA MediaSource at (240) 386-4200.
Broker DealerAsset Manager
The Securities and Exchange Commission announced today that it will host a roundtable on April 16, 2026, to discuss listed options market structure, including facilitating competition in a quote driven market, evaluating the customer experience, and…
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Broker DealerBank
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The CFTC announced on March 2, 2026, the appointment of David I. Miller, a former federal prosecutor and white-collar defense attorney, as Director of Enforcement, replacing acting director Paul Hayeck. This leadership change signals a potential shift toward stricter enforcement against fraud, market manipulation, and abusive trading practices, particularly in commodities and digital assets, while emphasizing the division's core policing role over policy-making. Compliance professionals should monitor this for evolving enforcement priorities, as Miller's prosecutorial background and digital asset experience may intensify scrutiny on high-risk activities.
What Changed
This announcement introduces no new regulatory rules, requirements, or statutory changes; it is a personnel appointment reshaping enforcement leadership. Chairman Selig highlighted Miller's role in refocusing the Enforcement Division on "policing fraud, abuse, and manipulation rather than setting policy," potentially signaling reduced pursuit of novel legal theories and a narrower enforcement scope.
What You Need To Do
- Review internal controls for fraud, manipulation, and abusive trading, prioritizing digital asset activities (e
- Assess exposure from Miller's past cases (e
- Monitor CFTC enforcement dockets and coordinate with counsel experienced in CFTC/SEC/DOJ matters for upcoming investigations
- Update training on "core" violations (fraud, abuse, manipulation) to align with stated enforcement focus
Key Dates
March 02, 2026 - Announcement and effective start of David I. Miller as Director of Enforcement .
June 2025 - Paul Hayeck began as acting director (historical context; Hayeck transitions to Complex Fraud Task Force chief).
Compliance Impact
Urgency: Medium. This matters because the new Director influences case selection, resource allocation, and prosecutorial priorities, potentially increasing enforcement momentum in commodities and crypto amid CFTC's staffing buildup and jurisdictional expansions. Firms with digital asset exposure face heightened risk of investigations into fraud/manipulation, but the "narrower" focus may reduce pursuits of expansive theories, offering predictability for compliant actors. Track for 3-6 months to observe initial actions.
Broker DealerCrypto ExchangeAll Firms
No description available.
The CFTC Enforcement Division issued an advisory on February 25, 2026, detailing two enforcement cases involving illegal trading on prediction markets (event contracts) traded on KalshiEX, a Designated Contract Market. The advisory clarifies that the CFTC maintains full enforcement authority over prediction markets and will prosecute violations including insider trading, market manipulation, and fraud—establishing critical compliance expectations for platforms and traders in this emerging asset class.
What Changed
The advisory does not introduce new rules but rather reaffirms existing CFTC enforcement authority over prediction markets and clarifies the scope of prohibited conduct:
Insider trading/misappropriation: Trading based on material nonpublic information obtained through a breach of fiduciary duty or pre-existing duty of trust and confidence (Section 6(c)(1) of the Commodity Exchange Act and Regulation 180.1(a)(1) and (3))
Fraud and manipulation: Use of manipulative schemes or artifices to defraud, including trading in contracts where the trader has direct or indirect influence over the...
What You Need To Do
- *For Prediction Market Platforms (DCMs)
- *Implement robust surveillance systems to detect trading by individuals with material nonpublic information or direct/indirect influence over contract outcomes
- *Establish clear trading prohibitions in exchange rules addressing:
- Trading in contracts where the trader has influence over the outcome
- Trading based on material nonpublic information obtained through breach of duty
Key Dates
February 25, 2026 - CFTC Enforcement Division issues Prediction Markets Advisory
May 2025 - First enforcement case (political candidate trading incident) identified and resolved by Kalshi
August-September 2025 - Second enforcement case (YouTube editor trading incident) identified and resolved by Kalshi
No specific future deadlines - Advisory does not establish new compliance deadlines; it clarifies existing obligations DEADLINE
Compliance Impact
Urgency: HIGH
Crypto ExchangeBroker Dealer
The Securities and Exchange Commission’s Division of Enforcement today announced significant updates to its Enforcement Manual. These updates underscore the Commission’s ongoing commitment to fairness, transparency, and efficiency in the investigations…
The SEC's Division of Enforcement announced updates to its Enforcement Manual on February 24, 2026, focusing on enhancing fairness, transparency, and efficiency in investigations through standardized procedures like the Wells process and settlement considerations. These changes, the first major revisions since 2017, introduce uniform timelines and best practices to streamline resolutions and improve dialogue with investigated parties. Compliance professionals should prioritize this as it directly affects how firms respond to SEC inquiries, potentially accelerating outcomes and reducing uncertainties in enforcement actions.
What Changed
The updates target investigative and enforcement procedures for greater consistency:
Uniform Wells process: Recipients of a Wells notice receive four weeks to submit responses; Wells meetings are scheduled within four weeks of submission and include senior Division leadership. Guidance is provided on effective submissions to foster dialogue and timely resolutions.
Simultaneous settlement and waiver consideration: Restores practice allowing settling parties to request Commission waivers from collateral consequences (e.g., disqualifications) alongside settlement offers, improving transparency...
What You Need To Do
- Review the updated Enforcement Manual (https
- Update internal policies for responding to Wells notices: Prepare submissions within four weeks, focusing on elements staff find "most helpful" (e
- For settlements, incorporate simultaneous waiver requests in offers to leverage restored process and mitigate collateral impacts
- Enhance cooperation strategies per new evaluation framework to potentially reduce civil penalties; document internal collaboration for enforcement interactions
- Monitor annual Manual reviews via SEC Division of Enforcement page (https://www
Key Dates
February 24, 2026 - Updates to Enforcement Manual announced and effective; last major revision was 2017, with annual reviews planned going forward.
Four weeks from Wells notice receipt - Standard deadline for Wells submissions. DEADLINE
Four weeks from Wells submission receipt - Scheduling of Wells meetings with senior leadership.
Compliance Impact
Urgency: High - These procedural updates are immediately effective and alter critical interaction points with SEC staff, such as Wells responses and settlements, which can determine investigation closure, enforcement recommendations, or penalty severity. Firms under active scrutiny or anticipating inquiries gain from predictable timelines reducing prolonged uncertainty, but must adapt quickly to avoid suboptimal outcomes; non-compliance risks inefficient resolutions or missed cooperation credits.
Asset ManagerBroker DealerHedge Fund No description available.
Broker DealerCrypto Exchange
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Crypto ExchangeAll Firms
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The CFTC has withdrawn its 2024 proposed rulemaking on "Event Contracts" (which sought to prohibit political event contracts) and the 2025 Staff Advisory (No. 25-36) on sports event contracts, signaling a policy shift under new Chairman Michael S. Selig toward promoting innovation via new rulemaking. This matters because it removes prior restrictive guidance, reduces immediate compliance burdens on prediction market operators, and opens the door for lawful event contracts while hinting at CFTC asserting exclusive jurisdiction over these derivatives.
What Changed
Withdrawal of the June 10, 2024, Notice of Proposed Rulemaking titled “Event Contracts,” which proposed prohibiting political event contracts as contrary to public interest (e.g., akin to war or terrorism outcomes); CFTC confirms no final rules will issue from this proposal.
Withdrawal of CFTC Staff Letter 25-36 (issued Sept.
What You Need To Do
- Review and disregard prior compliance programs built around the 2024 proposal or 2025 advisory (e
- Monitor CFTC docket for new event contracts rulemaking notice and provide comments during any future consultation period
- Assess current offerings for event contracts under existing Commodity Exchange Act prohibitions (e
- Evaluate litigation exposure, especially state gaming regulator actions; prepare for potential CFTC intervention asserting exclusive jurisdiction
- No immediate prohibitions lifted or mandates imposed—continue operating within current CEA framework (e
Key Dates
June 10, 2024 - Publication of withdrawn "Event Contracts" Notice of Proposed Rulemaking.
September 30, 2025 - Issuance of withdrawn CFTC Staff Letter 25-36 (Sports Event Contracts Advisory).
February 4, 2026 - CFTC announcement withdrawing both the 2024 proposal and 2025 advisory; no final rules from 2024 proposal; new rulemaking to advance.
Compliance Impact
Urgency: Medium – This withdrawal immediately eliminates overhang from restrictive proposals/advisories, allowing firms to pivot from prohibition compliance to innovation planning without urgent deadlines. It matters for reducing uncertainty in prediction markets but requires vigilance for new rules, jurisdictional fights, and insider trading clarity, as platforms like Polymarket face ongoing scrutiny.
Broker DealerFintechCrypto Exchange
No description available.
BankBroker DealerHedge Fund
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Crypto ExchangeFintechAll Firms
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Crypto ExchangeFintechAll Firms
The Securities and Exchange Commission today filed settled charges against Archer-Daniels-Midland Company (ADM) and its former executives, Vince Macciocchi and Ray Young, and a litigated action against its former executive Vikram Luthar, for …
Broker DealerAsset Manager
Electronic Communications
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Derivatives
Broker DealerAsset ManagerWealth Manager
Day Trading
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Customer Orders
Broker DealerAsset ManagerWealth Manager
Consolidated Audit Trail (CAT)
Broker DealerAll Firms
Conflicts of Interest
Broker DealerBankAsset Manager
Blue Sheets
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Best Execution
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Alternative Display Facility (ADF)
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Information Notice - 1/3/25
FINRA issued an Information Notice on January 3, 2025, modifying the Contrary Exercise Advice (CEA) cut-off time for options expiring on January 9, 2025, from the standard 5:30 p.m. ET to 10:00 a.m. ET due to the National Day of Mourning. This time-sensitive directive required immediate operational adjustments for all broker-dealers and clearing members handling options exercise instructions on that specific date.
What Changed
The primary regulatory modification addresses a single-day exception to standard options exercise procedures:
CEA Cut-Off Time Acceleration: The normal 5:30 p.m. ET deadline for submitting Contrary Exercise Advice was compressed to 10:00 a.m. ET on January 9, 2025.
Exercise Instruction Acceptance Window: Members could not accept exercise instructions for either customer or non-customer accounts after 10:00 a.m.
What You Need To Do
- *Update Internal Procedures
- *System Configuration
- *Staff Communication
- *Customer Notification
- *Submission Coordination
Key Dates
January 9, 2025 - 10:00 a.m. ET Final deadline for option holders to make exercise/non-exercise decisions and for members to accept exercise instructions (accelerated from standard 5:30 p.m. ET) DEADLINE
January 9, 2025 - 10:00 a.m. ET Final deadline for members to submit Contrary Exercise Advice to exchanges or OCC (accelerated from standard 5:30 p.m. ET or 7:30 p.m. ET depending on account type and submission method) DEADLINE
January 9, 2025 National Day of Mourning; national options exchanges closed; exercises in specified option classes prohibited
Compliance Impact
Urgency: HIGH (for January 9, 2025 operations; now historical)
Broker DealerAll Firms
Regulatory Notice 25-06
Broker DealerAsset Manager
Regulatory Notice 25-08
Broker DealerAsset Manager
Regulatory Notice 25-15
Broker DealerBank
Information Notice 11/17/25
FINRA Information Notice 11/17/25 reminds member firms of a modified exercise cut-off time for standardized equity options expiring on November 28, 2025, due to national options exchanges closing early at 1:00 p.m. ET on the Friday after Thanksgiving. This adjustment shifts the deadline for option holders' final exercise decisions from 5:30 p.m. ET to 2:30 p.m. ET under FINRA Rule 2360(b)(23)(A)(viii). It matters for compliance as firms must enforce this deadline to avoid regulatory violations, protect client positions, and manage operational risks during a holiday-shortened trading day.
What Changed
National options exchanges will close at 1:00 p.m. ET on November 28, 2025, triggering a modified exercise cut-off under FINRA Rule 2360(b)(23)(A)(viii): deadline is 1 hour 30 minutes after close (i.e., 2:30 p.m. ET), overriding the standard 5:30 p.m. ET.
Firms may set earlier internal deadlines for accepting exercise instructions but cannot accept any after 2:30 p.m.
What You Need To Do
- Update client communications
- Configure systems and procedures
- Train staff
- Monitor and record
- Contact FINRA contacts (James Turnbull or Matthew Vitek) for clarification
Key Dates
November 17, 2025 - Publication of FINRA Information Notice 11/17/25 reminding firms of upcoming modified cut-off.
November 28, 2025, 1:00 p.m. ET - Early close of national options exchanges.
November 28, 2025, 2:30 p.m. ET - Firm deadline to accept final exercise/not-exercise decisions (no later instructions permitted). DEADLINE
2026 ); relevant for historical compliance review or similar future holidays. DEADLINE
Compliance Impact
Urgency: low (post-event as of January 2026). This is a one-time reminder for a past holiday adjustment, with low risk of enforcement absent systemic failures. It matters operationally to prevent erroneous exercises, client disputes, or capital charges from uncollected exercise costs, but non-compliance could trigger FINRA surveillance reviews under Rule 2360. Firms should audit 2025 records now for lessons on future early-closes (e.g., Good Friday).
Broker Dealer
No description available.
FintechCrypto ExchangeAll Firms
No description available.
The CFTC announced three major enforcement actions on January 16, 2026, resolving cases involving **market manipulation (spoofing), misappropriation of confidential information, and unregistered commodity pool operations**. These cases demonstrate the CFTC's continued enforcement focus on fraudulent trading practices and registration violations, with combined penalties exceeding $685,000 and criminal sentences totaling over six years in prison.
What Changed
The enforcement actions establish precedent in three critical areas:
*Market Manipulation (Spoofing): The CFTC secured consent orders against precious metals futures traders for spoofing—placing and canceling orders to create false market impressions. The orders impose three-year and six-month trading bans** and require cease-and-desist compliance with the Commodity Exchange Act's spoofing prohibition.
*Misappropriation and Fictitious Trading: The CFTC obtained permanent injunctive relief requiring disgorgement of unlawful gains ($135,788) plus civil penalties ($200,000), with 18-month...
What You Need To Do
- *For Registered Futures Firms and Banks
- trade and post-trade compliance controls
- *For Commodity Pool Operators and Investment Advisors:
- by-jurisdiction licensing analyses before soliciting investors
- *For All Market Participants
Key Dates
September 2019 - CFTC enforcement action filed against Smith and Nowak
December 2021 - CFTC complaint filed against Miller and Omerta Capital; DOJ criminal charges filed
December 2022 - CFTC complaint amended against Miller and Omerta Capital
August 2023 - Smith and Nowak sentenced to prison (criminal case)
June 2024 - Miller sentenced to prison (criminal case)
Compliance Impact
Urgency: HIGH
The CFTC has announced enforcement updates, including civil monetary penalties and trading bans for spoofing in precious metals futures markets and misappropriating confidential information. These updates highlight the importance of compliance with CFTC regulations. Firms must ensure they are registered and comply with anti-spoofing and anti-fraud regulations.
What Changed
The CFTC has obtained federal court orders imposing civil monetary penalties and trading bans on individuals and firms for spoofing and misappropriating confidential information. The CFTC has also charged an unregistered commodity pool operator with fraud and registration violations.
What You Need To Do
- Verify registration with the CFTC at NFA BASIC before committing funds
- Review and update anti-spoofing and anti-fraud policies and procedures
- Ensure compliance with CFTC regulations regarding commodity pool operations and futures market participation
Key Dates
1 Sept 2021 CFTC enforcement action filed against Gregg Smith and Michael Nowak
10 Dec 2021 Department of Justice charged Peter Miller with conspiracy to commit commodities fraud
1 Jun 2024 Peter Miller sentenced to five months in prison and five months of home confinement
10 Dec 2024 Department of Justice charged Travis Ford with conspiracy to commit wire fraud
Non-Compliance Risk
Enforcement action, fines, trading bans, and registration revocation
Related Regulations
Commodity Exchange ActCFTC regulations
Confidence: high
Broker DealerAsset ManagerCrypto Exchange The Securities and Exchange Commission today announced that Paul H. Tzur and David M. Morrell have been named as Deputy Directors of the Division of Enforcement. Mr. Tzur joined the Commission on January 6, 2026, as the Deputy Director overseeing the…
The SEC announced on January 12, 2026, the appointment of Paul H. Tzur and David M. Morrell as Deputy Directors of the Division of Enforcement, with Tzur joining on January 6, 2026, to oversee key operations. This personnel change is part of a broader reorganization replacing Regional Directors with Deputy Directors for more centralized oversight of investigations. It matters for compliance teams as it signals greater consistency in enforcement approaches, potentially affecting investigation timelines, Wells process strategies, and settlement negotiations across SEC-regulated entities.
What Changed
This announcement reflects structural reforms rather than new substantive regulations:
Replacement of Regional Directors with Deputy Directors, centralizing reporting from local offices (e.g., Boston, Fort Worth, Atlanta) and specialized units directly to headquarters-led Deputy Directors.
Enhanced supervision of enforcement decisions, aiming for consistency and reduced regional variations in handling investigations.
Complements parallel Wells process reforms under Chairman Paul Atkins, including a baseline four-week response period, greater access to evidence, and senior-level meetings for...
What You Need To Do
- Review and update internal protocols for SEC investigations to align with centralized reporting structures, anticipating uniform standards across regions
- Train legal/compliance staff on refined Wells process (e
- Monitor upcoming SEC communications for Enforcement Director Judge Margaret Ryan's guidance on fraud-focused priorities
- Assess current or potential matters for earlier engagement with Deputy Directors on case theories and resolutions
Key Dates
January 6, 2026 - Paul H. Tzur joins SEC as Deputy Director of the Division of Enforcement.[User Query]
January 12, 2026 - SEC announces appointments of Paul Tzur and David Morrell as Deputy Directors.[User Query]
Compliance Impact
Urgency: Medium. This matters due to its role in ongoing SEC transition under Chairman Atkins and Director Ryan, promising more predictable enforcement but requiring adaptation to centralized decision-making and Wells enhancements. While not imposing immediate obligations, it could accelerate case resolutions and shift settlement dynamics, especially amid 2025's enforcement slowdown from staffing cuts (15-20% headcount reduction). Firms with active investigations should prioritize strategic adjustments now.
Asset ManagerBroker DealerHedge Fund The Securities and Exchange Commission today filed charges against purported crypto asset trading platforms Morocoin Tech Corp., Berge Blockchain Technology Co. Ltd., and Cirkor Inc. and investment clubs AI Wealth Inc., Lane Wealth Inc., AI Investment…
Crypto ExchangeBroker DealerAsset Manager
No description available.
Broker DealerCrypto Exchange
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BankBroker DealerCrypto Exchange
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The CFTC approved a final rule on December 18, 2025, that codifies existing staff no-action positions and eliminates duplicative business conduct and documentation requirements for swap dealers and major swap participants. This rule resolves over a decade of regulatory uncertainty, reduces operational costs, and harmonizes CFTC requirements with SEC and Municipal Securities Rulemaking Board standards.
What Changed
The final rule introduces the following substantive amendments:
*Exceptions for Swaps Intended to be Cleared (ITBC Swaps)**
Swap dealers and major swap participants are exempted from certain External Business Conduct Standards and swap trading relationship documentation requirements when executing swaps that are intended by the parties to be cleared contemporaneously with execution.
What You Need To Do
- *Immediate Actions (Pre-Implementation)
- *Implementation Actions (Upon Effective Date)
- trade disclosure systems to remove PTMMM generation and delivery requirements
- based operations, review implications of superseded Staff Letter No
- *Ongoing Compliance
Key Dates
April 4, 2025 - CFTC Staff Letter 25-09 issued, establishing no-action position on PTMMM requirement
September 12, 2025 - CFTC issued further amended exemptive order permitting JSCC to clear interest rate swaps
September 24, 2025 - CFTC issued Notice of Proposed Rulemaking (comment period opened)
October 24, 2025 - Comment period deadline (ISDA and SIFMA submitted comments on this date) DEADLINE
December 18, 2025 - CFTC approved final rule (subject to pre-publication technical corrections)
Compliance Impact
Urgency: HIGH
Broker DealerBank
The Securities and Exchange Commission today charged Canadian citizen Nathan Gauvin and three entities he controls—Blackridge, LLC, Gray Digital Capital Management USA, LLC, and Gray Digital Technologies, LLC—with orchestrating two fraudulent securities…
Broker DealerCrypto Exchange
The Securities and Exchange Commission today announced the agenda and panelists for its Dec. 16, 2025, roundtable on Rule 611 of Regulation NMS and other associated rules and regulatory requirements.The roundtable will be held at the University of Austin…
Broker DealerAll Firms
The Securities and Exchange Commission’s Crypto Task Force has announced the agenda and panelists for its rescheduled Roundtable on Financial Surveillance and Privacy.“New technologies give us a fresh opportunity to recalibrate financial surveillance…
BankBroker DealerCrypto Exchange No description available.
The CFTC filed a civil enforcement action on November 21, 2025, against Brian Mitchell, Kevin Mack Jr., and their unregistered entity Young Pros Investment Group LLC (YPIG) for fraudulently soliciting ~$1 million from 33 pool participants to trade commodity futures, using misrepresentations, Ponzi payments, false statements, and registration violations, including Mitchell's breach of a prior 2021 CFTC order. This case underscores the CFTC's aggressive enforcement against unregistered commodity pools and fraud, seeking restitution, disgorgement, penalties, trading bans, and injunctions under the Commodity Exchange Act (CEA). Compliance teams must prioritize registration checks and fraud prevention to avoid similar actions, as it highlights personal liability for controlling persons.
What Changed
This is an enforcement action, not a rulemaking, so there are no new regulatory changes or requirements. It reinforces longstanding CEA and CFTC rules on:
Mandatory registration as a Commodity Pool Operator (CPO) and Associated Persons (APs) for pools trading commodity futures (CFTC Regulation 4.13 exemptions do not apply here due to fraud and public solicitation).
Prohibitions on fraud, misrepresentations, guarantees of profit, non-disclosure of risks, commingling funds, and operating pools as non-separate entities (CEA Section 4o, Regulations 4.20, 4.21).
Compliance with prior CFTC orders...
What You Need To Do
- Verify registration
- Implement controls
- Conduct due diligence
- Train staff
- For SEC-registered advisers
Key Dates
2025 .
November 21, 2025 - CFTC files complaint in U.S. District Court for the Eastern District of Michigan.
~December 2020 - May 2022 - Alleged fraudulent solicitation and trading period.
2021 - Prior CFTC administrative order against Mitchell (Press Release 8427-21) prohibiting trading and registration activities for three years.
Compliance Impact
Urgency: High - This action signals intensified CFTC scrutiny on unregistered pools amid rising crypto/futures fraud (e.g., similar January 2026 case against Wolf Capital). It matters because penalties include personal bans, multimillion restitution/disgorgement, and whistleblower awards (10-30% of sanctions), amplifying financial/reputational risk; non-registration alone triggered charges alongside fraud. Firms with commodity exposure must audit operations immediately to preempt enforcement.
Hedge FundAsset ManagerAll Firms
The Securities and Exchange Commission announced today that it will hold a roundtable on Dec. 16, 2025, to discuss Rule 611 of Regulation NMS and other, associated rules and regulatory requirements. This roundtable is a follow-up to the SEC’s Sept. 18,…
Broker DealerAll Firms
The CFTC today announced the U.S. District Court for the Central District of California entered a final judgement against Safeguard Metals LLC and Jeffrey Ikahn (aka Jeffrey Santulan and Jeffrey Hill) ordering them to pay $25.6 million in restitution to victims and a $25.6 million civil monetary penalty for operating a nationwide, precious metals fraud. Released: 11/20/2025
The CFTC, alongside 30 state regulators, secured a final judgment on November 20, 2025, against Safeguard Metals LLC and Jeffrey Ikahn, imposing $25.6 million in restitution to victims and a $25.6 million civil monetary penalty for a nationwide precious metals fraud scheme from October 2017 to July 2021 that defrauded over 450 elderly investors of more than $52 million. This enforcement action, resolving a February 2022 complaint, highlights coordinated federal-state-SEC efforts to combat commodity fraud and underscores personal liability for controlling persons under CEA Section 6(c)(1) and Regulation 180.1(a). It matters for compliance as it reinforces aggressive penalties for misrepresentations, overcharges, and targeting vulnerable populations, with offsets across parallel SEC proceedings.
What Changed
This is an enforcement action, not a rulemaking, so there are no new regulatory changes or requirements. It reaffirms existing CEA prohibitions on fraud, including Section 6(c)(1), 7 U.S.C. § 9(1), and 17 C.F.R. § 180.1(a)(1)-(3), covering material misrepresentations, omissions, and deceptive schemes in precious metals sales.
What You Need To Do
- Conduct immediate fraud risk assessments on precious metals sales scripts, disclosures, and pricing markups to ensure no material misrepresentations or undisclosed overcharges
- Enhance senior investor protections, including suitability reviews, cooling-off periods, and training on vulnerable customer targeting bans
- Review controlling person policies for good faith oversight, documenting supervisory failures to avoid personal liability
- Audit parallel SEC/CFTC exposures in commodity-linked activities, preparing for offset calculations in multi-agency actions
- Update compliance manuals with this case as precedent for CEA fraud in physical commodities; monitor whistleblower notices for internal reporting incentives
Key Dates
February 1, 2022 - CFTC and states file initial complaint alleging fraud scheme.
May 5, 2022 - Plaintiffs file First Amended Complaint.
September 6, 2023 - Second Amended Complaint filed.
May 2, 2025 - Court enters SEC remedies judgment ($25.6M disgorgement/penalty, with offsets).
September 30, 2025 - Court issues Statement of Decision granting restitution ($25.6M) and civil penalty ($25.6M).
Compliance Impact
Urgency: Medium - This resolved enforcement sets precedent for precious metals fraud penalties but imposes no new rules or immediate deadlines beyond whistleblower claims (March 9, 2026). It matters due to escalating CFTC-state coordination, personal liability risks, and focus on elder fraud amid rising retail commodity scams; firms in metals or alternatives face audit risks if sales practices mirror the scheme (e.g., overcharges, false safety claims).
Broker DealerAsset ManagerAll Firms
No description available.
The CFTC issued an order on September 17, 2025, sanctioning Shinhan Securities Co. Ltd. with a $212,500 civil monetary penalty for engaging in wash sales and non-competitive transactions on NYMEX, involving near-simultaneous bids and offers for the same futures contracts under the same beneficial owner to avoid risk and price competition. This enforcement action underscores the CFTC's ongoing focus on market manipulation practices that undermine open and competitive trading, serving as a reminder for firms to enhance trade surveillance and compliance programs. Compliance professionals should note this as evidence of active CFTC scrutiny on wash trading violations under the Commodity Exchange Act (CEA).
What Changed
This is an enforcement action, not a rulemaking, so there are no new regulatory changes or requirements introduced. It reaffirms existing prohibitions under CEA Section 6(c)(2) against wash sales (fictitious sales) and non-competitive transactions that negate risk or price competition in futures markets. The case highlights CFTC's interpretation of wash sales as including trades where buy and sell orders for identical quantities of the same contract are executed near-simultaneously for accounts with the same beneficial owner, even if enhancing execution likelihood.
What You Need To Do
- Enhance trade surveillance
- Conduct gap analysis
- Strengthen internal controls
- Self-reporting consideration
- Training and recordkeeping
Key Dates
September 17, 2025 - CFTC issues order filing and settling charges against Shinhan, requiring immediate payment of $212,500 penalty and cease-and-desist order.
Compliance Impact
Urgency: Medium - This action signals sustained CFTC enforcement on wash sales amid broader anti-manipulation priorities, with penalties reflecting cooperation but still material ($212,500). It matters because wash trades erode market integrity, and recent advisories incentivize proactive remediation to reduce penalties; firms with similar trading patterns face heightened exam risk, especially post-2025 enforcement shifts toward disruptive practices like spoofing and wash trading.
Broker Dealer