1-Hour Program

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In the first four years after the Dodd-Frank Act prohibition on spoofing was signed into law in 2010, the CFTC resolved only one case relating to spoofing, and not a single criminal action was brought.  In the roughly four years since that time, spoofing charges and resolutions—both civil and criminal—have risen steadily, culminating most recently in actions against 3 organizations and 8 individuals (including both settlements and indictments) announced in coordinated press releases by the CFTC and Department of Justice on January 29, 2018. 

Please join Kathleen S. McArthur and Alexander J. Willscher, partners at Sullivan & Cromwell LLP as they:

  • Provide an overview of the prohibition against spoofing
  • Review recent enforcement actions by the CFTC and DOJ in this space
  • Offer practical insight into the criteria authorities have considered in evaluating what constitutes spoofing

Program Level:  Update

Intended Audience:  In-house counsel, outside attorneys, board members, and corporate officers

Prerequisites:  Background involving CFTC and DOJ enforcement, particularly with respect to spoofing 

Advanced Preparation:  None 


Credit Details