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March 11, 2019
Commentary by Bob Zwirb

The U.S. District Court for the District of Columbia entered a Consent Order ("Order") against a foreign trading platform and its CEO (collectively, the "Defendants") for unlawful bitcoin-related transactions with U.S. customers. The Order resulted from a September 2018 Complaint filed by the CFTC. According to the Order, the Defendants (i) illegally offered commodity transactions that were in the form of "contracts for difference" involving gold and crude oil, (ii) neglected to register as a futures commission merchant with the CFTC and (iii) failed to satisfy their supervisory

July 08, 2013

The NFA released July 2013 revisions to the Financial Requirements Section 16 and the related interpretive notice regarding cleared swaps customer collateral accounts. These updates are available in five appendices of policies that include: Compliance with theExchange Act Rule 15c3-1: the calculation of haircut charges on securities; additionally, charges on the more common securities are reviewed: government securities and Canadian debt obligations, municipal securities, other municipal securities, money market funds, commercial paper, bankers' acceptances and certificates of deposit, non