As we noted in our recent civil update, the pace of criminal cases related to Paycheck Protection Program (PPP) loan fraud has not slowed. Here are a few significant cases from the last several months.
Prediction markets allow their participants to trade event contracts based on binary outcomes of future events, ranging from the outcome of an NFL playoff game to how many times the Vice President will clap during the State of the Union. The price of these contracts (for example, a 30-cent event contract may pay $1 if the event occurs) reflects the market’s assessment of the probability that a given outcome will occur.
An AI agent scans a news alert, identifies a market opportunity, and places a trade in your brokerage account—all before you finish your morning coffee. This is not a hypothetical. It is the premise of Robinhood’s recently launched Agentic Trading platform, and it is a consequential development in AI-enabled financial services. It also arrives as the two primary federal regulators of U.S. financial markets, the Securities and Exchange Commission (SEC) and the Commodity Futures Trading Commission (CFTC), are actively building out AI governance frameworks.
In a rare exercise of federal emergency authority, on July 14, 2026, the Commodity Futures Trading Commission (CFTC) did two things that, individually, would each be unusual and together are noteworthy: it stayed an emergency rule self-filed by a regulated exchange, and then affirmatively ordered that exchange to honor contracts it had already proposed to unwind. The target was KalshiEX LLC (Kalshi), a CFTC-designated contract market (DCM) for event contracts. The catalyst was a Michigan state court order that the CFTC determined raised questions of federal preemption under the Commodity Exchange Act (CEA) and the functioning of a federally regulated derivatives market.
On June 30, 2026, I spoke with Jeff Le Riche and Sarah Razaq Sallis during the latest edition of Husch Blackwell’s Government Enforcement, Compliance & Investigations webinar series.
Earlier this month, the Commodity Futures Trading Commission (CFTC or Commission) eliminated its rule barring settlement with defendants who continued to deny the allegations against them. The move follows the Securities and Exchange Commission’s rescission of a parallel no-deny policy in May 2026, a development we noted previously, and signals an accelerating consensus shift between the two agencies on the terms of civil enforcement settlements.
Earlier this month, the U.S. Supreme Court issued its 9-0 decision in Sripetch v. Securities and Exchange Commission, holding that the U.S. Securities and Exchange Commission (SEC) can retrieve ill-gotten gains from alleged securities-law violators without having to prove that victims of those violations suffered a pecuniary loss.[1] Sripetch is the most recent decision in a series of U.S. Supreme Court cases analyzing the SEC’s disgorgement powers.
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.
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.
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.