Insights

Classification of Crypto Assets Under Federal Securities Laws

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Summary Situation Overview: This past Monday, the Securities and Exchange Commission (SEC) and the Commodity Futures Trading Commission (CFTC), published a highly anticipated interpretive release that lays the foundational groundwork for the…

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…

Understanding Regulatory Attention on Private Assets and AI Across Capital Markets and Insurance

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Summary 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

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Summary 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

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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…

Resolution Planning Faces Regulatory Uncertainty

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Summary 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:…

Is Your IT Risk Management Framework “Future-Proof”?

Summary Situation Overview: Technology risks constantly evolve.  Effective IT Risk Management Programs can identify, address and, as needed, adapt to emerging risks. This analysis illustrates how an effective IT Risk Management Framework can…

CFTC Swap Rules for Renewable Energy Transactions: What VPPA Participants Must Know

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Summary Situation Overview: Virtual power purchase agreements (VPPAs) are classified as swaps under the Commodity Exchange Act (CEA). All firms engaging in VPPAs are obligated to comply with certain CFTC regulations, including non-financial…

CFTC Issues No-Action Relief for Swap Data Reporting Error Corrections

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Summary Situation Overview: On December 10, 2025, the Commodity Futures Trading Commission (CFTC) issued no-action relief regarding the correction of errors in swap transaction and pricing data submitted to a swap data repository (SDR). What:…