Bridging the Week by Gary DeWaal: November 5 - 9 and November 12, 2018 (To Tell the Truth; Smart Contracts; Swaps Trade Execution Requirements)

Published Date: November 12, 2018

A swap dealer was fined US $12 million by the Commodity Futures Trading Commission for a host of purported noncompliance issues. It was also sanctioned for allegedly not disclosing in two annual chief compliance officer annual reports potential regulatory problems of which it was aware. Separately, the Securities and Exchange Commission penalized the founder and developer of an online platform that offered trading in ether and ERC20 digital tokens through an autonomous smart contract that interfaced with the Ethereum blockchain. The SEC claimed that the platform impermissibly operated as a national securities exchange when it did not have the requisite registration or did not transact in accordance with the terms of a valid exemption. Moreover, the SEC said that the founder of the trading platform should have foreseen the likely violation. As a result, the following matters are covered in this week’s edition of Bridging the Week:

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Gary DeWaal

Gary DeWaal is currently Special Counsel with Katten Muchin Rosenman LLP in its New York office focusing on financial services regulatory matters. He provides advisory services and assists with investigations and litigation.

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Gary DeWaal
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