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Enforcement Trends at the CFTC (Part One): A Regulator’s State of the Union

Trends in Trade Surveillance and Regulation   2018 was a record-breaking year for the CFTC and this point was brought home forcefully in a recent speech from Enforcement Director James McDonald. Speaking to the NYU School of Law, McDonald delivered a clear and forceful recounting of the enforcement actions that the agency undertook during the […]

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A Way Forward for Cryptocurrency Market Compliance

The cryptocurrency market is developing in real-time, right before our very eyes. Borne from the world of technology rather than the realm of finance, cryptocurrency markets understandably lack most of the features and functions that are taken for granted in traditional financial markets. Many of these shortcomings have been examined – and often exaggerated –

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FIA Asia 2018

FIA held their 14th annual Asia Derivatives Conference in Singapore from November 27 – 30 and the robust crowds, Brexit questions, and positive views regarding Chinese futures markets painted a rosy picture for industry growth in the region. Compared to the FOW Derivatives World Asia event in April (you can read our recap of that

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How To Protect Yourself When Using Intermarket Sweep Orders and Breaking the Order Protection Rule

“With great power comes great responsibility” – Voltaire (or Spider Man’s Uncle Ben)   As the fairly controversial and seemingly very expensive SEC tick pilot comes to a close in October, it’s a good time to reflect on the very interesting exemptions to Rule 611, specifically the use of Intermarket Sweep Orders (ISOs) and their

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IOP Surveillance-Critical Component of a Comprehensive Trade Surveillance Program

The focus of regulators and exchanges continues to sharpen and recent interest has zeroed in on the activity prior to the opening of the market. In products where an Indicative Opening Price (IOP) is utilized, regulatory action and fines have come down for behaviors that are deemed to be manipulative. To assist firms in managing

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