Insights

Rulemaking on Prediction Markets: Key Takeaways from CFTC ANPR

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Summary Situation Overview: On March 12, the Commodity Futures Trading Commission (CFTC) issued an Advanced Notice of Proposed Rulemaking (ANPR) relating to event contracts traded on prediction markets. This ANPR constitutes one of the most…

Combatting AI-Enabled Fraud – A Top Financial Crime Threat

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Summary Situation Overview: In January 2026, the Association of Certified Anti-Money Laundering Specialists (ACAMS) published its 2026 Global Anti-Financial Crime Threats Report (ACAMS Report). The ACAMS Report identified artificial intelligence…

Prediction Market Surveillance: CFTC Advisory and SRO Enforcement Action

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Summary Situation Overview: Kalshi announced that it pursued enforcement actions against two participants for alleged manipulative trading activity. The CFTC also issued a related Prediction Markets Advisory reaffirming its oversight authority…

OCC GENIUS Proposal: Three Policy Issues to Watch

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Summary Situation Overview: The Office of the Comptroller of the Currency (OCC) issued a notice of proposed rulemaking (NPR) to implement the Guiding and Establishing National Innovation for U.S. Stablecoins Act (GENIUS Act). The NPR addresses…

A New Chapter for Shareholder Proposals: Best Practices for Navigating the 2026 Proxy Season

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Summary Situation Overview: In November 2025, the U.S. Securities & Exchange Commission’s (SEC) Division of Corporation Finance announced that, for the 2025–2026 proxy season, it will no longer issue substantive “no-action” letters…

CFTC Chair Outlines Priorities for Prediction Markets and Digital Asset Market Structure

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Summary Situation Overview: On January 29, Commodity Futures Trading Commission Chair Michael Selig made his first public remarks at the CFTC-SEC harmonization event. Among other things, Chairman Selig laid out the agency’s priorities, which…

CFTC Eases SDR Error Notification Requirements With New No-Action Relief

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Summary: Situation Overview: On July 31, 2025, the Commodity Futures Trading Commission (CFTC) provided reporting counterparties relief from the swap data repository (SDR) reporting requirement to submit an error correction notification (ECN)…

The Future of U.S. Crypto Regulation: Analyzing the CLARITY Act and the RFIA

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Summary: Context: The U.S. Congress is actively developing a robust regulatory framework to govern digital assets, aiming to provide clarity and stability to the rapidly evolving industry. What: The House of Representatives passed the CLARITY…

FDIC Highlights Policy Priorities Impacting FinTechs and Large Banks

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Summary: Situation Overview: FDIC is focused on de novo bank formation, digital assets and blockchain activities, resolution planning, and asset thresholds for “tailoring” categories. What: The FDIC is reevaluating guidance in these…

BlockFi Settlement Shows SEC Applying Old Rules to Crypto

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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…

Digital Currencies’ Role in Facilitating Ransomware Attacks: A Brief Explainer

Patomak’s Kristine Johnson co-authored a paper for Third Way that details how Bitcoin—the most popular digital currency—is used to facilitate ransomware attacks and how criminals try—and sometimes fail—to cover their tracks. Understanding how criminals use digital currencies for ransomware attacks can lead policymakers to solutions in thwarting and enforcing cybercrimes.

Morning Consult: Billions of Dollars Have Migrated to the Blockchain. Now What?

Token Alliance co-chairs Paul Atkins and Jim Newsome write in an op/ed in Morning Consult: The private sector drives innovation; it is one of the best characteristics of the American economy. In contrast, the government operates deliberately and carefully. That is why we worked with Token Alliance, an initiative of the Chamber of Digital Commerce representing more than 350 blockchain and token experts from around the globe, to develop a comprehensive set of guidelines now to help shape the responsible growth of the token marketplace. The collaborative report is designed to be used as a resource among industry innovators, consumers, and policymakers to address so-called “utility tokens,” an aspect of the token economy fighting to be recognized.