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ARTICLE · 20 SEPTEMBER 2018

New Commission Moves Quickly On Enforcement

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Within a week of the ceremonial swearing in of its last commissioner, the now fully formed Commodity Futures Trading Commission issued 17 enforcement orders and filed one complaint.

United StatesCriminal Law

Within a week of the ceremonial swearing in of its last commissioner,1 the now fully formed Commodity Futures Trading Commission2 (Commission or CFTC) issued 17 enforcement orders and filed one complaint.3 These initial enforcement actions were brought against a wide range of market participants and address four broad areas: (1) fraud and manipulation; (2) record-keeping and supervision; (3) reporting; and (4) registration. Significantly, continuing a trend started last year,4 in all four areas, the Commission highlighted the importance of cooperation.

I. Fraud and Manipulation

On September 14, 2018, the CFTC's Division of Enforcement (Division), under Director James McDonald, filed a civil enforcement action in the U.S. District Court for the Southern District of New York against an unregistered dealer and one of its owners. The complaint alleged that the defendants defrauded retail clients in connection with precious metals transactions, fraudulently obtaining

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