by Sudhir Jain, Elsa Paul Castro and Anika Horowitz | Dec 12, 2022 | Patomak Post
On December 2, the CFTC reminded non-U.S. swap dealer chief compliance officers of annual reporting requirements. This Staff Advisory asserts that many non-U.S. swap dealers have been deviating from chief compliance officer annual reporting requirements. Dually...
by Keith Noreika, Sudhir Jain and Joshua Kuntz | Nov 22, 2022 | Patomak Post
Effective and comprehensive risk management is key to the cryptocurrency industry’s future success. The industry would mitigate various risks by following the five principles described here. The recent bankruptcy of a major cryptocurrency exchange came as a surprise...
by Jill Sommers, Jamila Piracci, Sudhir Jain and Nick Grose | Nov 15, 2022 | Patomak Post
CFTC and NFA have issued more than 15 enforcement orders against swap dealers in 2022. Five key pitfalls stand out as a common denominator: failure to report to Swap Data Repositories, failure to provide sufficient disclosures to counterparties, failure to diligently...
by Paul Watkins, Sudhir Jain and Laura Magyar | Feb 28, 2022 | Patomak Post
The recent BlockFi settlement with the Securities and Exchange Commission (SEC) made clear that the agency considers certain digital-asset product offerings “securities” under two long-standing tests. The action also marked the application of an additional regulatory...
by Jamila Piracci, Ted Serafini and Sudhir Jain | Feb 14, 2022 | Patomak Post
Outgoing Commodity Futures Trading Commission (CFTC or Commission) Commissioner Dawn Stump recently issued a challenge to her fellow commissioners to move past simply enforcing the CFTC’s rules as they exist and to do the hard work of setting more clearly defined...
