SEC affirms FINRA decision to fine CCO $5K.

Late last year the Securities and Exchange Commission (SEC) released an opinion affirming a FINRA decision to fine a CCO for “failure to enforce WSP” (written supervisory procedures). The firm, Ocean Cross had approximately 15 associated persons and two principals in two offices between September 8, 2011 and April 30, 2012—the relevant period in this […]

Former Vitol trader indicted on FCPA charges.

In the first of what is thought to be many Foreign Corrupt Practices Act (FCPA) charges to be brought to the energy trading community, a former Vitol trader was indicted on FCPA charges by the Department of Justice (DoJ). A previously sealed indictment (see here) was unsealed yesterday outlining the government’s case against Javier Aguilar. […]

New Position Limit Proposal

Overview Ten years after the passing of the Wall Street Accountability Act a.k.a. Dodd Frank the Commodity Futures Trading Commission (CFTC) held a public meeting yesterday to bring forth the fifth attempt at proposing a position limit rule. Over the last 10 years the CFTC has attempted four position limit proposals. In 2011 one proposal […]

DOJ Compliance Program Guidance

Earlier this year the Department of Justice (DoJ) issued two publications for prosecuting attorneys to provide guidance on assessing the effectiveness of corporate compliance programs. The two publications (April 2019 and July of 2019) further develop and update the “Evaluation of Corporate Compliance Programs,” issued by the Criminal Division’s Fraud Section released in February 2017 […]