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In June 2018, we published an article discussing the government’s efforts to prosecute defendants who engage in a form of trading activity on commodity futures exchanges known as “spoofing,” which the law defines as “bidding or offering with the intent to cancel the bid or offer before execution.” See, Jodi Misher Peikin & Brent M. Tunis, “When Is a Bid or Offer a ‘Spoof’?,” Business Crimes Bulletin (June 2018). In that article, we observed that the failure of the Commodity Futures Trading Commission (CFTC) to define what specific conduct qualifies as spoofing has left market participants uncertain about when cancellation of a bid or offer crosses the line from an acceptable trading strategy to an illegal “spoof.” This ambiguity is compounded by the fact that rapid cancellation of orders is prevalent in the commodities markets. See, Richard Haynes & John S. Roberts, CFTC, “Automated Trading in Futures Markets” at 9 (2015) (“[J]ust over 50 percent of market orders are cancelled within half a second, approximately the speed of human reaction.”).
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Common Pitfalls In Personal Device Collection
By Marjorie Peerce and Marguerite O’Brien
Both the DOJ and the SEC have made it clear that they will look at company BYOD policies when assessing how to resolve matters under their purview. To avoid pitfalls — and sanctions — counsel must take proactive steps to ensure proper preservation and collection of personal mobile data and verify that clients comply.
FCPA Compliance Guidance for Global Businesses
By Cole Callihan
The Biden administration and its Justice Department have established countering corruption as a core U.S. national security interest. Companies with any international operations should ensure they have a robust written policy and compliance program focused on anti-bribery and corruption.
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By Karen Hoffman-Lent and Kenneth Schwartz
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Will the Corporate Transparency Act Smother the Cannabis Industry?
By Steve Schain
The CTA requires business entities to file information on their “beneficial owners” with FinCEN, which, in turn, may disclose it to domestic and foreign law enforcement agencies, prosecutors, judges and financial institutions.
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