On May 8, 2019, the Division of Enforcement (“Division”) of the Commodity Futures Trading Commission (”CFTC”) announced that it had published its Enforcement Manual (“Manual”). This is the first issuance of a public Manual. Prior to this publication, the Manual was only available internally as a general reference to the Division’s Staff during their investigation

Anna Biegelsen (US)
Anna is an associate in Norton Rose Fulbright's Washington, DC office. She focuses her practice on regulatory, compliance, enforcement and transactional issues for energy and commodity companies and financial institutions participating in US energy markets.
CFTC Chair hails the accomplishments of the past year’s enforcement program
On October 2, 2018, Commodity Futures Trading Commission (“CFTC”) Chairman J. Christopher Giancarlo spoke before the Economic Club of Minnesota, giving a detailed overview of the CFTC’s enforcement program for fiscal year 2017 (Oct. 2017 – Sept. 2018), entitling his remarks “Regulatory Enforcement & Healthy Markets: Perfect Together!”
The CFTC’s enforcement program filed…
CFTC’s Giancarlo’s Cross-Border White Paper 2.0 signals upcoming rule proposals to replace cross-border guidance
On October 1, 2018, the Commodity Futures Trading Commission’s (“CFTC”) Chairman, J. Christopher Giancarlo released a White Paper entitled, “Cross-Border Swaps Regulation Version 2.0: A Risk-Based Approach with Deference to Comparable Non-U.S. Regulation” (“Cross-Border White Paper 2.0”). Chairman Giancarlo intends to direct the CFTC staff to put forth new rule proposals, which if…
Security-based swap reporting rules published by the SEC
The Securities and Exchange Commission on February 11 published the texts of two final rules and one proposed rule that establish reporting requirements for security-based swaps (SBSs). These rules, previously adopted by the SEC in a meeting on January 14, 2015, create a reporting regime for SBSs that largely parallels the swaps reporting regime adopted…