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Articles by Stephan Ariyan
CFTC's Gunewardena Flags Gaps in Cross-Border Derivatives Oversight
CFTC Director of International Affairs Mel Gunewardena warned that international regulatory architecture has not kept pace with markets that are becoming continuous, programmable, composable, and autonomous. He gave his remarks at a joint Regulation Week conference hosted by the George Washington University Regulatory Studies Center and the Fundação Getulio Vargas Center for Law and Regulation.
CFTC Warns Event Contract Markets on Misleading Pricing
The CFTC's Division of Market Oversight and its Market Participants Division warned regulated entities that list, solicit, or accept event contracts to display clear and accurate pricing information and avoid misleading consumers (see prior coverage). In a staff letter, the divisions stated that displaying pricing information in the "American odds" format used by casino gambling bookmakers is likely to mislead market participants about the nature of the transaction.
CFTC Extends Comment Period on 24/7 Trading and Energy Perpetual Contracts
The CFTC extended the comment deadline on its request for comment on extending standard futures to 24/7 trading and on perpetual contracts referencing physically delivered or storable energy commodities, moving it from July 27, 2026, to August 26, 2026 (see prior coverage). The CFTC also added a request for comment on the self-certified 24/7 oil contract that NYMEX listed on July 8, 2026, and that the CFTC stayed on July 9, 2026 (see prior coverage).
CFTC Sunsets Routine Large Trader Reporting for Physical Commodity Swaps
The CFTC issued a final order terminating the routine reporting requirements of Part 20 ("Large Trader Reporting for Physical Commodity Swaps"). Affected firms are no longer required to submit the daily consolidated-account position data records and event-based reports previously mandated under Part 20's clearing organization and reporting entity provisions.
CFTC charts a path forward on perpetuals and 24/7 derivatives markets
Authors: Mark Highman, Stephan Ariyan, Sebastian Souchet, Gage Raju-Salicki Introduction Over the course of the last few months, the Commodity Futures Trading Commission (CFTC) has taken a number of significant actions that clarify the CFTC’s regulatory framework regarding both perpetual contracts and trading in derivatives markets on a 24/7 basis.
SIFMA and FIA Urge CFTC to Clarify Regulatory Approach to Prediction Markets
SIFMA and the Future Industry Association ("FIA") called on the CFTC to establish clearer regulatory standards for prediction markets.
NYAG Sues Prediction Markets, as in Violation of State Gaming Law
"As an unlicensed gambling business, Respondent operates without implementing required consumer protections and internal controls that are part of New York’s strict regulation of licensed gambling." New York State V. Coinbase Financial Markets "As an unlicensed gambling business, Respondent operates without implementing required consumer protections and internal controls that are part of New York’s strict regulation of licensed gambling." New York State V.
CFTC advances regulatory framework for prediction markets
On March 12, 2026, the Commodity Futures Trading Commission took two significant actions furthering the development of a regulatory framework for prediction markets. First, the CFTC issued a staff advisory outlining current regulatory expectations for listing and trading event contracts on prediction markets. Second, the CFTC published an advance notice of proposed rulemaking, signaling the intent to develop a comprehensive regulatory framework for these markets. Read our alert here.
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