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Abstract: 

Federal regulators, and their self-regulatory organization and exchange counterparts, continue to signal an aggressive and determined approach to their enforcement of relevant law and regulations. They continue to pursue sanctions zealously for activity they believe interferes with the efficient operation of the commodity futures markets and continue to serve as watchdogs over the industry’s interactions with the public. Moreover, they appear eager to address head-on the changing technological environment in which the markets function — whether it be to exercise broad jurisdiction over the digital asset industry, or to take action against firms and individuals whose modern communication tools do not appear to meet traditional recordkeeping strictures. Industry members would be wise to fortify their legal and compliance infrastructures to meet these challenges, and to expect continued close scrutiny by the organizations and agencies that oversee them.

Keywords: In re Glencore International A.G., and Chemoil Corporation; Spoofing Prosecutions; Swaps Reporting and Swap Dealer Business Conduct; Digital Assets

Affiliations:  1: Davis Wright Tremaine LLP; 2: Davis Wright; 3: Davis Wright.