Corporate Compliance

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On June 10, 2026, the U.S. Commodity Futures Trading Commission (CFTC) published a Notice of Proposed Rulemaking (NPRM) seeking public comment on amendments to CFTC Regulation 40.11 and the addition of a new Appendix F to part 40, addressing event contracts, commonly traded on so-called “prediction markets.” The proposal would specify which event contracts may be subject to a determination that they are contrary to the public interest, set out the factors the Commission would apply, and add a definition of “gaming” together with a rule for when an event contract “involves” an underlying activity.

Washington, D.C., USA- January13, 2020: Sign of The U.S. Commodity Futures Trading Commission (CFTC) at its headquarters in Washington, an agency of the US government.

Amid recent high-profile incidents of suspicious activity on prediction markets, as well as pressure from Congress, the CFTC has signaled in unmistakable terms that prediction markets are squarely within its enforcement crosshairs and that it will use every tool at its disposal—including artificial intelligence surveillance.

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In April 2026, U.S. Army Special Forces Master Sergeant Gannon Ken Van Dyke was charged for allegedly profiting over $400,000 on bets placed on an offshore cryptocurrency-based prediction platform using classified information related to a military operation targeting former Venezuelan President Nicolás Maduro. The prosecution of Van Dyke reflected the government’s position that prediction markets are subject to the Commodity Exchange Act’s (CEA) anti-fraud and insider trading prohibitions.

Less than six weeks later, federal prosecutors have filed a second insider trading claim involving prediction markets–this time alleging use of confidential corporate data on Polymarket, the world’s largest online prediction marketplace.

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On May 19, 2026, the Commodity Futures Trading Commission’s (CFTC) Division of Enforcement (Division) issued CFTC Letter No. 26-15, a staff advisory establishing a comprehensive new policy on self-reporting, cooperation, and remediation. The policy creates clear incentives for proactive compliance and early disclosure of potential misconduct.

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We just released Episode 42 of the False Claims Act Insights podcast where Tim Ribelin and I discussed managed care FCA enforcement.

Tim recently discussed this topic at an American Conference Institute conference. Our listeners now get to hear Tim’s takes on “one way” or “add-only” chart reviews, and how aggressive documentation templates create FCA…

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On February 24, 2026, the Securities and Exchange Commission’s Division of Enforcement announced sweeping revisions to its Enforcement Manual (the Manual). A central feature of the revisions is a redesigned Wells process, which gives investigation targets a chance to be heard before the Commission authorizes an enforcement action. Most notably, the revised manual instructs staff to provide Wells notice recipients with “salient, probative evidence” before a response is due, addressing the information imbalance that has traditionally characterized SEC investigations. Then, on May 18, 2026, the SEC announced a second major pro-defendant shift: it rescinded Rule 202.5(e)—the decades-old “no-deny” policy that had required settling defendants to agree not to publicly deny the agency’s allegations as a condition of settlement.

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We just released Episode 41 of the False Claims Act Insights podcast where I discussed the often ignored but critical issue of relators’ attorneys’ fee petitions. Relators often claim millions of dollars of fees at the end of False Claims Act settlements, and some are shocked to learn that federal law requires the party settling…

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On December 19, 2025 and January 30, 2026, the United States Sentencing Commission released proposed amendments to the Federal Sentencing Guidelines for 2026. See U.S. Sentencing Comm’n, Proposed 2026 Amendments to the Federal Sentencing Guidelines (Dec. 2025 and Jan. 2026). Taken together, these amendments suggest a meaningful recalibration of how federal sentences may be calculated and, for some defendants, an opportunity for more individualized and potentially less severe outcomes.