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What the heck does “annual” mean, anyway?

  ♦AML and Cybersecurity: A Tale of Two Deadlines♦ Earlier this year the National Futures Association published Cybersecurity FAQs to provide guidance supplemental to its Interpretive Notice on information systems security. This statement in particular caught our attention: "A Member will meet the annual requirement if…
Joseph Adamczyk
June 17, 2019
News

Just released: New Anti-Money Laundering course

  ♦Death, Taxes and AML Training♦ If your firm is an FCM, IB or BD, one of life's certainties is that your employees (those involved in account solicitation, account opening, customer service, order execution, finance or treasury) need to take Anti-Money Laundering training every year. To…
Joseph Adamczyk
June 4, 2019
News

A Must-Read: CFTC Enforcement Manual

  ♦An Agency First: CFTC DOE Enforcement Manual♦ The new Enforcement Manual issued by the Commodity Futures Trading Commission's Division of Enforcement is a significant 59-page document. It consolidates a wealth of information that was previously scattered among various enforcement decisions and memoranda. The manual…
Joseph Adamczyk
May 23, 2019
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“Regulatory creep” on the spoofing front

  ♦U.S. vs. Thakkar: Non-Traders Beware♦ One of the most fascinating panel discussions at last week's Futures Industry Association Law & Compliance Conference in Washington, D.C. focused on the recent Jitesh Thakkar spoofing case. The panel included moderator Marc Nagel, an attorney and chief consultant…
Joseph Adamczyk
May 16, 2019
News

You Better Know the Nuances

  ♦Market Conduct Update: Pre-Open Guidance♦ CME Group released a Market Regulation Advisory last week to provide guidance on Globex pre-open activity. The advisory, which becomes effective April 25, covers order entry practices, disruptive trade practices and wash trades. The 26-page document is intended as…
Joseph Adamczyk
April 18, 2019
News

CME Advisory: EFRPs Better Be Bona Fide

  ♦CME Advisory: Off-Market EFRPs Will Be Scrutinized♦ In an amended Market Regulation Advisory Notice that became effective yesterday, CME Group tightened the screws on Exchange for Related Position (EFRP) transactions that are not up to snuff. As reported by Gary DeWaal on March 11…
Joseph Adamczyk
March 22, 2019
News

CFTC 2019 Exam Priorities

  ♦An Overview of CFTC 2019 Exam Priorities♦ (The following article was posted on February 19, 2019 in Securities Law Perspectives by Nicholas J. Wendland, and is reprinted with his permission. Mr. Wendland is of Counsel at Drinker Biddle & Reath LLP.) In an effort…
Joseph Adamczyk
February 26, 2019
News

An Ounce of Prevention is Worth a Pound of Cure

♦Block Out the Big Penalty♦ When the NYMEX Business Conduct Committee fined an introducing broker Jan. 31 for block trade reporting violations, the panel found that, among other issues, the firm failed to properly advise its employees as to relevant Exchange rules. The fine: $135,000…
Joseph Adamczyk
February 12, 2019