Andrew Yodis

Feb 14, 2024 | lexology.com | Paul Tyrrell |Jay G. Baris |Elizabeth Shea Fries |Stephen Cohen |Timothy J. Treanor |Stanley J. Boris | +1 more

On February 13, 2024, the U.S. Treasury’s Financial Crimes Enforcement Network (FinCEN) withdrew its 2015 notice of proposed rulemaking (NPRM) related to registered investment advisers (RIAs) and released a new notice of proposed rulemaking seeking to impose anti-money-laundering/counter-terrorist financing (AML/CTF) program requirements for the U.S. Securities and Exchange Commission (SEC) RIAs along with SEC exempt reporting advisers (ERAs).1 The addition of ERA as a covered investment...

Jan 22, 2024 | lexology.com | Christopher Lee |Steven Sexton |Joanna R. Travalini |Paul Tyrrell |Casey Khan |Andrew Yodis

On January 8, 2024, the Fifth Circuit Court of Appeals reversed a $6.5 million jury verdict, holding that the U.S. Commodity Futures Trading Commission (CFTC) failed to provide fair notice of its interpretation of a decades-old rule preventing commodities traders from “taking the other side of orders” without clients’ consent.1 The Fifth Circuit noted that this was a case of first impression and agreed with EOX Holdings LLC (EOX) and its commodities broker, Andrew Gizienski, that the CFTC...