The CFTC’s New Enforcement Manual Guidance Details Factors Used in Corporate Compliance Programs

The CFTC’s New Enforcement Manual Guidance Details Factors Used in Corporate Compliance Programs

The Commodity Futures Trading Commission (“CFTC”) has announced Division of Enforcement staff-level guidance that outlines whether a company’s compliance program was reasonably designed and implemented to (i) prevent the underlying misconduct at issue; (ii) detect the misconduct; and (iii) remediate the misconduct. At all points, the Division will conduct a risk-based analysis, taking into consideration

Braden Perry Discusses The Consumer Data Privacy and Security Act In the Washington Examiner

Braden Perry Discusses The Consumer Data Privacy and Security Act In the Washington Examiner

The Consumer Data Privacy and Security Act is a bill by Kansas Republican Sen. Jerry Moran, one of the many privacy bills in Congress right now. If the bill is passed, it would add 440 employees to the FTC’s 1,000-plus workforce. Kennyhertz Perry partner, Braden Perry, is featured in a Washington Examiner article discussing Moran’s

Unregistered Commodity Pool Operator and It’s Principal Charged with Fraud in Missouri

Unregistered Commodity Pool Operator and It’s Principal Charged with Fraud in Missouri

A civil enforcement action was filed today in the U.S. District Court for the Eastern District of Missouri against Joshua Christian McDonald, and his company Perfection PR Firm LLC (PPR), by the Commodity Futures Trading Commission.  McDonald’s company, out of California and Tennessee, was charged for an off-exchange foreign currency trading scheme of fraud and

Five Big Name Technology Firms to be Examined by FTC

Five Big Name Technology Firms to be Examined by FTC

Alphabet Inc., Amazon.com, Inc., Apple, Inc., Facebook, Inc. and Microsoft Corp. were issued Special Orders from the Federal Trade Commission (FTC) demanding they make available information and documents on acquisitions unreported to antitrust agencies under the Hart-Scott-Rodino (HSR) Act.  The order requests documents discussing terms, scope, structure and reason for transactions from these big name

Braden Perry Featured in Disruptor Daily Series on Blockchain and Agriculture

Braden Perry Featured in Disruptor Daily Series on Blockchain and Agriculture

Kennyhertz Perry, LLC Partner, Braden Perry was featured as one of several Blockchain experts in two Disruptor Daily articles on Blockchain in the agriculture industry. Perry discussed growth and the future of Blockchain in agricultural businesses. Perry has extensive experience advising clients in agricultural business and Blockchain, particularly in enforcement matters involving complex emerging and

CFTC and CME Charge Trader for Violations Related to Live Cattle Futures

CFTC and CME Charge Trader for Violations Related to Live Cattle Futures

The Chicago Mercantile Exchange (CME) and Commodity Futures Trading Commission (CFTC) issued an Order filing and settling charges against Nathan Harris, a registered trader, for fraud, unauthorized trading, and violating speculative position limits in live cattle futures contracts. It’s alleged that between January 2012 and August 2014, Harris engaged in fraud and unauthorized trading by