The United States is a Federation, which means that our States have a certain degree of independent authority. Many states have legalized cannabis for medicinal or recreational use, but the U.S. Government’s continues to view marijuana as an illegal substance. This creates distinct and challenging problems for the cannabis industry. One area of concern
In its 2018 annual report, the SEC showed that during the fiscal year that ended on September 30, 2018, both the volume of the SEC’s enforcement activity and the level of financial recoveries increased compared to the prior fiscal year. These numbers included increased activity in public companies and signals an increased scrutiny on the
Nearly two-thirds of America’s states, including Missouri, have legalized marijuana for certain uses, but the federal government still classifies marijuana as a “Schedule 1” drug, on a par with heroin. This presents an interesting problem for financial institutions: technically, financial transactions involving marijuana-related businesses (“MRBs”) would involve funds derived from illegal activity. Taking money from
Two recent cases in the news demonstrate the dangers of failing to consider judicious management of intellectual property rights with regard to products that include expressive content or identifiers. The wildly popular video game – Fortnite – includes animated dances that are sold to game players as “emotes.” The emotes can then be attached to
Private Industry Notification (PIN) 20190102-001 was being distributed to make private sector partners aware of the exploitation of audio visual communication devices on networks to identify vulnerabilities which could later be used to gain access and unlawfully acquire information about the organization. The alert was released as TLP: Green and the details, including useful information
In a recent decision, a Southern District of New York court found the Commodity Futures Trading Commission (“CFTC”) failed to prove DRW Investments, LLC (“DRW”) manipulated the price of an exchange-traded interest rate swap futures contract known as the IDEX USD Three-Month Interest Rate Swap Futures Contract. The CFTC alleged that DRW placed bids during
FINRA fined Morgan Stanly $10 million after finding it failed to properly supervise an anti-money laundering (“AML”) program over five years because of three major issues: First, Morgan Stanley’s automated AML surveillance system failed to receive data from several systems. Second, it failed to devote sufficient resources to review alerts generated by its automated AML surveillance
Braden Perry, a former CFTC Senior Trial Attorney that works in areas of novel and emerging technology with a financial focus, was featured in an NB Finance article on Commodity Trading. “Commodity trading is known to be extremely volatile and the risks are great,” Perry said. “There are many (fewer) CTAs than traditional asset managers or
The Commodity Futures Trading Commission (CFTC) recently announced an Order of default judgment and permanent injunction has been issued against defendants Capital Growth Group Associates and Cobra Development Group in connection with two separate fraudulent commodity pool trading schemes. The default was granted in the U.S. District Court for the Central District of California, and
Braden Perry, a regulatory and enforcement attorney that works in areas of novel and emerging technology with a financial focus, was featured in Meeting Professionals International (MPI) article on the Marriott data breach. “Vendors have a lot of data,” Perry said. “When it comes to supply chains, it is critical to monitor and review your
Braden Perry, a regulatory and enforcement attorney that works in areas of novel and emerging technology with a financial focus, was featured in Finance Magnates year-end review on the regulatory inaction in cryptocurrency. “The major takeaway is the regulatory treatment is (still) unclear for cryptocurrency,” he told Finance Magnates. “It seems as if every federal
Today, The Commodity Futures Trading Commission (CFTC) announced today that Defendant Mark R. Slobodnik, operating as Blue Guru, LLC, was ordered to pay approximately $370,000 in fines in connection with a $1.76 million commodity pool fraud. The Order stems from a CFTC Complaint alleging that Slobodnik, a former member of the Chicago Mercantile Exchange (CME),
