Recent Articles & Comments

The Xie case should serve as a reminder to commodity and derivative trading companies subject to US law to review and update company policies, codes of conduct, trading guidelines, or employment agreements regarding duties owned by employees to the company.

Self-reporting has long been a difficult decision, as the considerations vary by regulator, company and conduct. Beyond the issues raised in these remarks, firms need to consider the totality of the circumstances when deciding whether to self-report.