Insights

Rulemaking on Prediction Markets: Key Takeaways from CFTC ANPR
Derivatives Pamela Geraghty, Andrew Bonney Risk Management & ComplianceSummary
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
AML, Sanctions, & CFIUS Diane Daley, Heather Espinosa Risk Management & ComplianceSummary
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
Derivatives Colm Davidson, Harper Swope, Robert Lulgjuraj, Tim Brown, Sudhir Jain Risk Management & ComplianceSummary
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
Banking & Consumer Finance, Digital Assets Andrew Grub, Sam Canavos, Mona Elliot, Keith Noreika Risk Management & ComplianceSummary
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…

Vice Chair Bowman Elaborates on Supervisory Priorities and Examination Approach
Banking & Consumer Finance Diane Daley, Heather Espinosa Risk Management & ComplianceSummary
Situation Overview: In a recent speech, Vice Chair for Supervision Bowman reiterated the Federal Reserve’s supervisory operating principles and described how the Fed’s supervision should work in practice.
What: Firms should…

Understanding Regulatory Attention on Private Assets and AI Across Capital Markets and Insurance
Banking & Consumer Finance Andrew Grub, Mona Elliot Risk Management & Compliance, Strategy & AdvisorySummary
Situation Overview: Private assets and artificial intelligence (AI) are playing an increasingly prominent role across the financial system, including in capital markets and insurance. These developments are unfolding against a backdrop…

Regulatory Key Non-Financial Focus Areas: Financial Crimes, Fintechs, Digital Assets and AI
Banking & Consumer Finance, Digital Assets Diane Daley, Heather Espinosa Risk Management & ComplianceSummary
Situation Overview: Against the backdrop of deregulation, we expect regulators to continue to focus on financial crimes as well as fintech partnerships, digital assets, and artificial intelligence (AI).
What: Firms must keep compliance…

A New Chapter for Shareholder Proposals: Best Practices for Navigating the 2026 Proxy Season
Securities Cory Jack, Laura Magyar Risk Management & ComplianceSummary
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
Derivatives, Digital Assets Sam Canavos, Sudhir Jain Risk Management & Compliance, Strategy & AdvisorySummary
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…

Resolution Planning Faces Regulatory Uncertainty
Banking & Consumer Finance Diane Daley, Heather Espinosa Risk Management & ComplianceSummary
Situation Overview: A U.S. bank regulator signaled potential relaxation of resolution planning requirements for banks, while the Financial Stability Board (FSB) reiterated its support and focus on enhancing resolution planning capabilities.
What:…

