In a joint statement, the CFTC, FinCEN and the SEC reminded those engaged in digital asset transactions to comply with anti-money laundering and countering the financing of terrorism obligations under the Bank Secrecy Act.
The CFTC Division of Swap Dealer and Intermediary Oversight clarified the circumstances in which Customer Identification Program and Beneficial Ownership regulations under the Bank Secrecy Act do not apply to "voice" brokers.
On Monday, March 25, 2019, Cadwalader partners Jodi Avergun and Steven Lofchie will host a SIFMA Lunch & Learn demonstration of how technology can be leveraged to keep pace with regulatory uncertainty.
Recently adopted guidance requires NFA commodity pool operators to (i) implement an internal controls framework designed to protect customer funds, and (ii) provide assurance that the books and records of commodity pools are accurate.
The National Futures Association proposed an Interpretive Notice that requires commodity pool operators to adopt internal control systems to deter fraud, protect customer funds and pool assets, and assure the accuracy of records.
The SEC and CFTC filed separate charges against the operator of an online trading platform and its CEO for violating several federal securities and commodities exchange laws in connection with swaps and security-based swaps funded with bitcoins.