This WilmerHale program led by Partner Anjan Sahni, former Chief of the Securities and Commodities Fraud Task Force in the United States Attorney's Office for the Southern District of New York, and Partner Paul Architzel, co-chair of WilmerHale's Futures and Derivatives practice, covered recent CFTC regulatory and enforcement developments.
With respect to enforcement, Mr. Sahni provided insights into recent enforcement cases, the role of the Department of Justice in those cases, the future outlook for the increasing criminalization of futures and securities violations, the new focus on reporting violations and recent whistleblower awards.
Mr. Architzel discussed the current state of the CFTC's regulatory agenda—what has been accomplished and what remains to be done, including the recently finalized guidance on clearinghouse recovery and resolution; the still-pending proposals relating to positions limits, Regulation AT, cybersecurity, and harmonization of the SEF rules with the EU; and the challenges faced by the Commission during an election year.
