Patomak’s Anne Montminy, Senior Director, authored an article in the July/August 2026 issue of the Futures & Derivatives Law Report examining surveillance of prediction markets within the CFTC regulatory framework, with a focus on oversight of market participants’ access to, and use of, material non-public information.

In the report, Anne outlines the antifraud and anti-manipulation provisions that apply to exchanges and to all market participants, including DCM core principles, CFTC Regulation 180.1, and the February and March 2026 CFTC guidance confirming that the misappropriation theory of insider trading reaches these markets. She details five surveillance challenges specific to event contracts, including outcome and oracle manipulation, the expanded population of potential insiders created by real-world settlement events, fundamentally linked contracts, and offshore regulatory fragmentation, and sets out pre-trade and post-trade measures firms can implement now, from restricted person controls and defined information windows to detection thresholds, resolution source monitoring, and governance around alert review and escalation.

Read the full article here.