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Abstract: 

In FY 2024 the Commodity Futures Trading Commission’s (“CFTC”) continued its aggressive enforcement agenda with ever-increasing civil monetary penalties for industry participants. It embraced new methods of rule interpretation and enforcement areas while receiving criticism from sitting Commissioners and suffering losses in the court system. This criticism and losses will present challenges for the CFTC and the industry as we look to the future.

Keywords: TOTSA TotalEnergies Trading; Raizen Energia; Canadian Imperial Bank of Commerce; Piper Sandler Hedging Servs; Barclays Bank; Position Limits; Non-Disclosure Agreements; DeFi Protocols; Falcon Labs; Trafigura

Affiliations:  1: Davis Wright Tremaine LLP; 2: Davis Wright Tremaine LLP.