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Within the Government Enforcement, Compliance & Investigations Report, we plan to bring you periodic updates from the Commodity Futures Trading Commission (CFTC). In this first one, we are excited to announce a new addition to our team (and co-author of this post)—Jeff Le Riche. Jeff joins us after 20 years with the CFTC. We are thrilled to have him on board.

Now on to our updates from the CFTC.

White House Withdraws Nominee to Lead CFTC

On September 30, the White House withdrew its nominee for CFTC chairman, Brian Quintenz. A White House official stated that same day that a new nominee would be announced “in the near future,” but this individual has yet to be named. Quintenz, a former CFTC commissioner, recently faced opposition from  certain cryptocurrency industry players who reportedly urged President Trump to reconsider his nomination.

Since the departure of former commissioner Kristin Johnson on September 3, 2025, acting Chairman Caroline D. Pham remains the sole head of the CFTC. However, Pham stated in May 2025 that she intends to leave the agency for private practice as soon as her successor is confirmed.

Policy Statement on Criminal Regulatory Enforcement

On September 5, the CFTC released a policy statement outlining the agency’s plan to address regulatory offenses that potentially carry criminal penalties. The statement formalizes the guidance from the CFTC’s advisory letter on this topic, which we explained in detail in our prior update.

The CFTC reiterated that within the year it will provide the Director of the Office of Management and Budget a report listing all criminal regulatory offenses enforceable by either the CFTC or the Department of Justice (DOJ), the range of criminal penalties for each offense, and the applicable mens rea.

10 Firms Reach Settlements Pursuant to CFTC’s “Enforcement Sprint”

On September 4, the CFTC issued six orders both filing and settling violations against 10 companies for a total of $8,325,000 in civil penalties. Each of these firms took advantage of the CFTC’s “30-Day Compliance and Remediation Initiative” announced in March, during which registered entities were offered the opportunity to voluntarily come forward to the CFTC’s Division of Enforcement (DOE), disclose any compliance-related issues that did not involve customer harm and market abuse, explain their remediation measures, and make a settlement offer for the DOE’s consideration.

Charles Marvine, the Acting Chief of the Retail Fraud and General Enforcement Task Force, called the initiative a “success,” commenting that it helped the CFTC conserve resources, clean up its docket, and further its goal of focusing enforcement resources on fraud and other material wrongdoing.

The involved firms were ordered to pay $5 million for failing to diligently supervise trade surveillance systems; $1.5 million for failing to file and maintain large trader reports and regulatory records; and $325,000 over errors in their valuation methodology.

The civil penalties were determined using the CFTC’s recently released Mitigation Credit Matrix for Self-Reporting, Cooperation, and Remediation, which we covered in February 2025.

Stakeholders Asked to Comment on Tokenized Collateral and Stablecoins Initiative

On September 23, Acting Chairman Caroline D. Pham announced an initiative to introduce tokenized collateral, such as stablecoins, into derivatives markets. This new proposal is part of the Crypto Sprint, the agency’s initiative to support growth and innovation in the digital assets space.

 The press release accompanying the initiative highlights the following areas for public comment:

  • A November 21, 2024, report published by the Global Markets Advisory Committee’s (GMAC) Digital Asset Markets Subcommittee, which includes recommendations on the CFTC’s treatment of eligible tokenized non-cash collateral 
  • CFTC observer status on industry efforts
  • Potential digital asset markets pilot programs
  • Amendments to CFTC regulations in connection with the President’s Working Group report recommendations regarding collateral management

The comment period closes on October 20, 2025.

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The government shutdown has certainly slowed the amount of regulatory and enforcement activity, but once it ends, we will continue to keep you informed on the CFTC’s priorities, initiatives, and other notable developments.

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Photo of Jeff Le Riche Jeff Le Riche

Jeff counsels financial institutions, trading firms, and market participants across a broad range of asset classes, including futures, swaps, foreign currency, digital assets, commodities, and securities. He represents clients in civil and criminal government investigations and enforcement actions, internal investigations, litigation, and regulatory…

Jeff counsels financial institutions, trading firms, and market participants across a broad range of asset classes, including futures, swaps, foreign currency, digital assets, commodities, and securities. He represents clients in civil and criminal government investigations and enforcement actions, internal investigations, litigation, and regulatory compliance matters.

Photo of Kip Randall Kip Randall

A former Army officer, Kip now helps corporate and individual clients navigate government investigations. Kip counsels clients through investigations by the Securities and Exchange Commission (SEC); Environmental Protection Agency (EPA); Internal Revenue Service (IRS); Department of Justice (DOJ), including allegations of antitrust and

A former Army officer, Kip now helps corporate and individual clients navigate government investigations. Kip counsels clients through investigations by the Securities and Exchange Commission (SEC); Environmental Protection Agency (EPA); Internal Revenue Service (IRS); Department of Justice (DOJ), including allegations of antitrust and False Claims Act violations; and state attorneys general. As a member of the eDiscovery Solutions group, Kip works at the intersection of eDiscovery and Government Investigations.

Photo of Sydney Sznajder Sydney Sznajder

Sydney focuses on white collar defense, internal investigations, and compliance work. Sydney’s path to working as a white collar attorney began as a corporate editor at a risk investigative consultancy, where she edited risk reports and summaries of internal investigations for high-profile businesses.

Sydney focuses on white collar defense, internal investigations, and compliance work. Sydney’s path to working as a white collar attorney began as a corporate editor at a risk investigative consultancy, where she edited risk reports and summaries of internal investigations for high-profile businesses. She enjoyed helping researchers communicate complex legal and commercial challenges and developed an interest in understanding the law and its relationship to the corporate world.