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…

FSOC Releases Digital Asset Report, Signaling Increased Future Scrutiny

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A recent digital asset report (“Report”) issued by the Financial Stability Oversight Council (“FSOC”) criticized many digital asset market activities and market participants for lacking sufficient risk controls or amplifying financial…

Our Op-Ed in the American Banker: An Unworkable Compromise on Stablecoins

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The crypto industry yearns for legislative clarity on stablecoins, but the industry and consumers may be better off under the status quo than a flawed compromise. A one-size-fits-all approach could squash innovation. Expanding Federal…

RealClearMarkets: A Federal Power Grab Over the Future of Stablecoins

The President’s Working Group Report on Stablecoins is an important first step for federal regulators to develop a regulatory approach. Unfortunately, the report is a slap in the face to state regulators as it ignores their years of regulatory experience.