2015 CFTC Year-in-Review, and a Look Forward

Summary: CFTC continues to bring high-profile, large-penalty enforcement cases; begins bringing cases to enforce Dodd-Frank Act implementing regulations; and embarks on post-Dodd-Frank Act regulatory initiatives.

I. Introduction

2015 marked another active and record year for the Commodity Futures Trading Commission's (CFTC or Commission) enforcement program. The CFTC brought several high-profile cases under its new anti-manipulation authority and its new anti-spoofing authority. The Commission also set a new record for the largest fine collected in its history. In using its new anti-manipulation authority, the Commission began to set forth how it interprets the elements and scope of that authority and courts have begun to weigh in on these interpretations. We expect that the Commission will continue to aggressively use all of its enforcement authorities under the Commodity Exchange Act (CEA), including the new authorities added by the Dodd–Frank Wall Street Reform and