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…

