PLI White Collar Crime 2023 Keynote Speech of Enforcement Director Ian McGinley: “Enforcement by Enforcement: The CFTC’s Actions in the Derivatives Markets for Digital Assets”

Thank you for your affectionate introduction. As a general rule, start with a normal arrangement. These comments are considered to be my personal, and do not oblige the opinions of the Product Futures Transactions Committee (CFTC), the committee members, and the CFTC staff.

I have been a CFTC lawyer for half a year. Later, he has been working at the Federal Office in the southern part of New York (SDNY) for more than 10 years, is one of the most difficult scams and cyber crimes chapters, and is also an ambitious group member of a fighting securities fraud and product fraud. 。 For me, it is very honored to be in charge of the main report and advertise in the current program that has been on a long way. As a listener who receives Cle-Loan, as a member of the discussion on this issue, or as a keynote speaker this time, I have been providing short and important information from those who work on the earth for a long time. I wanted.

From the stage of arriving at CFTC, I was surprised by the vastness of CFTC regulations, in addition to the talent and loyalty of employees. The CFTC adjustable derivative market is widely exposed, including product futures, options, and swaps.

In connection with the data, there was a contradiction when thinking about where to focus on this concert. In the title of the printed matter, I may have to play a role in discussing the "regulation of compulsory methods" in the digital asset market. This line means excess of regulatory authorities when specific products and comparison are inadequate legislation and adaptation. But instead, when I talked about a adjustable spot for digital assets, according to Beknam's sentence, "CFTC is a task caused by the evolution of digital assets. In addition, in the jurisdiction area, in a framework that complies with the requirements of laws and regulations, as the market and market members are active, "[1] CFTC surprisingly process this task. Speaking of numbers, CFTC has now published 115 cases related to digital assets, and 33 cases have been announced since this year. And these cases are very important: the court or committee has reached a conclusion related to fines, refunds, and compensation for more than $ 4. 3 billion. < SPAN> Thank you for your loving introduction. As a general rule, start with a normal arrangement. These comments are considered to be my personal, and do not oblige the opinions of the Product Futures Transactions Committee (CFTC), the committee members, and the CFTC staff.

I have been a CFTC lawyer for half a year. Later, he has been working at the Federal Office in the southern part of New York (SDNY) for more than 10 years, is one of the most difficult scams and cyber crimes chapters, and is also an ambitious group member of a fighting securities fraud and product fraud. 。 For me, it is very honored to be in charge of the main report and advertise in the current program that has been on a long way. As a listener who receives Cle-Loan, as a member of the discussion on this issue, or as a keynote speaker this time, I have been providing short and important information from those who work on the earth for a long time. I wanted.

From the stage of arriving at CFTC, I was surprised by the vastness of CFTC regulations, in addition to the talent and loyalty of employees. The CFTC adjustable derivative market is widely exposed, including product futures, options, and swaps.

In connection with the data, there was a contradiction when thinking about where to focus on this concert. In the title of the printed matter, I may have to play a role in discussing the "regulation of compulsory methods" in the digital asset market. This line means excess of regulatory authorities when specific products and comparison are inadequate legislation and adaptation. But instead, when I talked about a adjustable spot for digital assets, according to Beknam's sentence, "CFTC is a task caused by the evolution of digital assets. In addition, in the jurisdiction area, in a framework that complies with the requirements of laws and regulations, as the market and market members are active, "[1] CFTC surprisingly process this task. Speaking of numbers, CFTC has now published 115 cases related to digital assets, and 33 cases have been announced since this year. And these cases are very important: the court or committee has reached a conclusion related to fines, refunds, and compensation for more than $ 4. 3 billion. Thank you for your affectionate introduction. As a general rule, start with a normal arrangement. These comments are considered to be my personal, and do not oblige the opinions of the Product Futures Transactions Committee (CFTC), the committee members, and the CFTC staff.

I have been a CFTC lawyer for half a year. Later, he has been working at the Federal Office in the southern part of New York (SDNY) for more than 10 years, is one of the most difficult scams and cyber crimes chapters, and is also an ambitious group member of a fighting securities fraud and product fraud. 。 For me, it is very honored to be in charge of the main report and advertise in the current program that has been on a long way. As a listener who receives Cle-Loan, as a member of the discussion on this issue, or as a keynote speaker this time, I have been providing short and important information from those who work on the earth for a long time. I wanted.

From the stage of arriving at CFTC, I was surprised by the vastness of CFTC regulations, in addition to the talent and loyalty of employees. The CFTC adjustable derivative market is widely exposed, including product futures, options, and swaps.

In connection with the data, there was a contradiction when thinking about where to focus on this concert. In the title of the printed matter, I may have to play a role in discussing the "regulation of compulsory methods" in the digital asset market. This line means excess of regulatory authorities when specific products and comparison are inadequate legislation and adaptation. But instead, when I talked about a adjustable spot for digital assets, according to Beknam's sentence, "CFTC is a task caused by the evolution of digital assets. In addition, in the jurisdiction area, in a framework that complies with the requirements of laws and regulations, as the market and market members are active, "[1] CFTC surprisingly process this task. Speaking of numbers, CFTC has now published 115 cases related to digital assets, and 33 cases have been announced since this year. And these cases are very important: the court or committee has reached a conclusion related to fines, refunds, and compensation for more than $ 4. 3 billion.

What I am trying now is how CFTC has dealt with this issue, the execution of a specific field, which is an important part of the data obtained from more than 115 cases, that is, the digital asset derivative market. To explain in detail. As is well known, derivatives are financial products in which prices, such as samples and physiological products, are dependent on something else. Digital assets have been derivative for a long time, and the first derivative product of Bitcoin was registered in 2014. I believe that social understanding has almost lost its precedent. In fact, CFTC has been pursuing important exchanges for about 10 years in this field, while many preceding opinions have been given under the leadership of Benam. Almost last week, he announced a reconciliation with three Defi platforms that provide no n-regulation derivative products.

First of all, we will briefly outlaw the CFTC mission and purpose, and then look back on the remarkable activities of CFTC in the digital asset derivative case, introduce that history has been better, and finally states our ideas.

Most people do not understand the role of CFTC, which provides meaningful regulations and monitors and executes traffic rules through execution to protect the soundness of the derivative market. Historically, the Derivative Market has helped South American farmers and livestocks to protect the price risk of the entire supply chain, such as drought, storms, wars, and changes in international trade. Eventually, the derivative market has expanded, providing products to manufacturers, pension funds, and financial institutions that require further risk management, such as financial risks and interest rate risks. By managing risks and providing a method to set prices, the derivative market has the economic power of the price that affects the daily life of everyone, from food to gasoline, building materials, to mortgage rates. It promotes prediction possibilities. < SPAN> What I am trying now is how CFTC has dealt with this issue, a specific field, which is an important part of the data obtained from more than 115 cases, a digital asset derivative. It is to explain in detail the market execution. As is well known, derivatives are financial products in which prices, such as samples and physiological products, are dependent on something else. Digital assets have been derivative for a long time, and the first derivative product of Bitcoin was registered in 2014. I believe that social understanding has almost lost its precedent. In fact, CFTC has been pursuing important exchanges for about 10 years in this field, while many preceding opinions have been given under the leadership of Benam. Almost last week, he announced a reconciliation with three Defi platforms that provide no n-regulation derivative products.

1. Most people do not understand the role of CFTC, which provides meaningful regulations and monitors and executes traffic rules through execution to protect the soundness of the derivative market. Historically, the Derivative Market has helped South American farmers and livestocks to protect the price risk of the entire supply chain, such as drought, storms, wars, and changes in international trade. Eventually, the derivative market has expanded, providing products to manufacturers, pension funds, and financial institutions that require further risk management, such as financial risks and interest rate risks. By managing risks and providing a method to set prices, the derivative market has the economic power of the price that affects the daily life of everyone, from food to gasoline, building materials, to mortgage rates. It promotes prediction possibilities. What I am trying now is how CFTC has dealt with this issue, the execution of a specific field, which is an important part of the data obtained from more than 115 cases, that is, the digital asset derivative market. To explain in detail. As is well known, derivatives are financial products in which prices, such as samples and physiological products, are dependent on something else. Digital assets have been derivative for a long time, and the first derivative product of Bitcoin was registered in 2014. I believe that social understanding has almost lost its precedent. In fact, CFTC has been pursuing important exchanges for about 10 years in this field, while many preceding opinions have been given under the leadership of Benam. Almost last week, he announced a reconciliation with three Defi platforms that provide no n-regulation derivative products.

First of all, we will briefly outlaw the CFTC mission and purpose, and then look back on the remarkable activities of CFTC in the digital asset derivative case, introduce that history has been better, and finally states our ideas.

1. Based on the Product Exchange Law, the US Congress has opened, transparent, competitive, and healthy, and has all of the failures in the CFTC, preventing and suppressing market failures, and all of them. It has given the rules aimed at protecting market participants from fraud, operation, and abuse, and the authority to adopt and enforce generally accepted measures. At the same time, there is an obligation to encourage meaningful innovation and fair competition. CFTC pursues his goals through trading facilities, liquidation systems (Central Counter Party), effective voluntary regulations on market participants, market experts, direct directors, and powerful execution programs. [3]

The Product Exchange Law is still the most rooted law in protecting individuals from fraud and abuse. The first trigger of the law was in a bucket shop from the 19th and early 20th centuries. [4] These "bucket shops" were not regulated and are often negligible companies. People were able to speak about food fees, provided the best profits and simple solutions, but then looted their customers' accounts for their purpose and traded with their customers to make customers. I completely wiped out. In other texts, inadvertent market participants in no n-regulated markets used people who were susceptible to wealth for their interests. [5] < SPAN> Based on the Product Exchange Law, the US Council forms a financially healthy market for CFTC, and has a financially healthy market, preventing and suppressing fraud and market failure. It has given the rules aimed at protecting all market participants from fraud, operation, and abuse, and the authority to adopt and enforce the general approved measures. At the same time, there is an obligation to encourage meaningful innovation and fair competition. CFTC pursues his goals through trading facilities, liquidation systems (Central Counter Party), effective voluntary regulations on market participants, market experts, direct directors, and powerful execution programs. [3]

The Product Exchange Law is still the most rooted law in protecting individuals from fraud and abuse. The first trigger of the law was in a bucket shop from the 19th and early 20th centuries. [4] These "bucket shops" were not regulated and are often negligible companies. People were able to speak about food fees, provided the best profits and simple solutions, but then looted their customers' accounts for their purpose and traded with their customers to make customers. I completely wiped out. In other texts, inadvertent market participants in no n-regulated markets used people who were susceptible to wealth for their interests. [5] Based on the Product Exchange Law, the US Congress has opened, transparent, competitive, and healthy, and has all of the failures in the CFTC, preventing and suppressing market failures, and all of them. It has given the rules aimed at protecting market participants from fraud, operation, and abuse, and the authority to adopt and enforce generally accepted measures. At the same time, there is an obligation to encourage meaningful innovation and fair competition. CFTC pursues his goals through trading facilities, liquidation systems (Central Counter Party), effective voluntary regulations on market participants, market experts, direct directors, and powerful execution programs. [3]

The Product Exchange Law is still the most rooted law in protecting individuals from fraud and abuse. The first trigger of the law was in a bucket shop from the 19th and early 20th centuries. [4] These "bucket shops" were not regulated and are often negligible companies. People were able to speak about food fees, provided the best profits and simple solutions, but then looted their customers' accounts for their purpose and traded with their customers to make customers. I completely wiped out. In other texts, inadvertent market participants in no n-regulated markets used people who were susceptible to wealth for their interests. [5]

In order to deal with such abuse and damage caused by individuals and larg e-scale products and futures markets, parliament established the futures Transactions Law in 1921, and the Future Exchange to the Secretary of Agriculture as the "contract market". Given the authority to be specified. After the Supreme Court concluded that the futures Transactions Law was unconstitutional as the exercise of the taxit rights of Congress, the parliament enacted the seedlings futures law. The law was based on the stat e-o f-th e-art trade regulations, and did not license futures transactions outside the contract market. Eventually, the parliament enacted the Product Exchange Law in 1936 and established the Product Exchange Management Bureau under the Ministry of Agriculture. The Exchange Administration Bureau was replaced by CFTC by the 1974 product futures and trading committee law. In the 1974 method, not only became an independent organization, but also the definition of "products" subject to the Product Exchange Law may be subject to futures contracts from the list of agricultural products. It has expanded to all applications, rights, and profits. [7]

1. As with 100 years ago, today's digital asset trader faces the risk of fraud and abuse. The risk is expanded by the possibility of trading with an underlying company with a high possibility of transparency, integrity, and payment ability.

What is the role of the European Committee on Digital Asset Derivatives?

overview

Current status of digital asset regulations

It is perhaps to the surprise of people unrelated to the derivatives industry that there is now a considerable amount of work that can be adjusted, because the adjustment design developed by the back eyelid in response to the rise of the "bucket" is also used for derivatives for digital assets. Under the Commodity Act, the CFTC refers to derivatives based on digital assets, for example, the way we relate to large cattle and soybeans, that is, under the influence of the Commodity Exchange Act and the Commission's orders in general, they are supposed to comply with these laws. In this way, you can now trade bitcoin or ether futures or options on an exchange regulated by the CFTC, while being subject to all the same legal and normative columns as if you were trading futures or options on gold, wheat or oil [8].

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CFTC's First Enforcement Action on Digital Assets - TheraExchange, Coinflip, Bitfinex Exchanges

For the adjustment regime to work, it is necessary to ensure a level playing field. If the main grounds, customer defense, market practices and other CFTC If there is a way to offer such products, inflating the regime so that the bottom of the adaptation system does not apply. To protect the adjustment system and protect the market and market participants, the European Commission is pursuing the negligence of hosts in the digital asset product field.

In 2015, the old-fashioned situation in the digital asset world - the European Commission's enforcement opinions on digital assets were published with two claims: CoinFlip and Terra Exchange. CoinFlip announced a product that "connects customers and sellers of standardized options and futures on Bitcoin" and listed its own Bitcoin-Call platform county with Bitcoin as the underlying asset. The European Commission investigated these products and noted for the first time that Bitcoin is considered a commodity. The Commission found that these products are considered swaps that have every opportunity to be negotiated only in designated contract markets or swap implementation centers registered with the Commission, pursuant to the Commodity Exchange Act. In its disposition, CoinFlip stated that by offering these products, CoinFlip was acting as an unregistered exchange, and as a result, indicated how its legal counsel spoke, “cease and desist” and, as one member of the public put it, “cease and desist from engaging in any illegal activity.”[9]

Around the time Coinflip was making headlines, the CFTC was pursuing a case against a CFTC-registered company called TeraExchange. TeraExchange registered as a swap exchange execution facility (SEF) and listed certain forms of digital asset derivatives. After its launch, TeraExchange arranged for two parties (the only two parties with trading authority on the exchange) to enter into what Tera then called “return transactions,” swaps based on Bitcoin, with similar entry and exit costs (i. e. no results; no profit or loss). A Tera employee also initiated a video call with one of the investors, who completed his first position and six minutes later completed a second position that economically offset the first. This is “soap opera” trading, a trading pattern that our laws have always prohibited. “Soap opera” trading provides false information to the market, misleads other market participants about the relative real demand for a commodity, and creates a false sentiment about the larger size of the trade. This is exactly what TeraExchange did. The exchange advertised the position as the "first [B]itcoin derivatives position held flawlessly on a regulated exchange." In other words, the first bitcoin derivatives plot held on a regulated exchange had the unfortunate honor of being frozen by a specific exit point.

In 2016, the European Commission took action against BitFinex, a foreign company that offered digital asset derivative products without registering with the European Commission.[11] Bitfinex operated an online platform for trading various digital assets and offered leveraged and margin trading. The Commodity Exchange Act only allows for margin, margin and funded retail commodity trading on exchanges registered with the CFTC, with some exceptions, and Bitfinex did not consider this an option. The Commission imposed a civil penalty and ordered Bitfinex to cease all forms of unregulated activity.

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1. These cases were at the beginning, two years ago, when the first bitcoin futures contract were listed on major exchanges. As the digital asset derivative market mature, the execution activities of the European Commission have been mature. In recent years, the European Commission has filed a larg e-scale exchange litigation on digital asset derivatives.

A remarkable example is a revolutionary lawsuit against Bitmex and three founders in 2021. The European Commission, who acted in parallel with criminal authorities, illegally operates a digital asset derivative trading platform, and "knows the customer" (KYC) Program and Money Laundering Procedure (AML) procedure (AML). Instead of implementing, he filed a lawsuit for violating the CFTC rules and violating the regulations of the Product Exchange Law and the European Commission. The client '(Kyc), customer information program, and ant i-money laundering (AML) procedures violated the CFTC rules. [12] According to the complaint, the company accepted at least 85., 000 US customers with more than $ 11 billion assets, intentionally involved in marketing and transactions for US customers. Furthermore, the complaint is to encourage US customers to use VPNs by US customers, for example, to hide the location of customers, or to train US customers to register offshore companies to trade with BitMex. He argues that it intentionally avoided US regulations.

The European Commission's measures ultimately have made a decision on companies and founders. This decision prevents Americans trading on the BitMex trading platform, as well as the $ 100 million individuals who are responsible for the company in involved. In fact, there was a wide range of relief measures aimed at dismantling the US business function of BitMex. < SPAN> These cases were at the beginning, two years ago, when the first bitcoin futures contract were listed on major exchanges. As the digital asset derivative market mature, the execution activities of the European Commission have been mature. In recent years, the European Commission has filed a larg e-scale exchange litigation on digital asset derivatives.

A remarkable example is a revolutionary lawsuit against Bitmex and three founders in 2021. The European Commission, who acted in parallel with criminal authorities, illegally operates a digital asset derivative trading platform, and "knows the customer" (KYC) Program and Money Laundering Procedure (AML) procedure (AML). Instead of implementing, he filed a lawsuit for violating the CFTC rules and violating the regulations of the Product Exchange Law and the European Commission. The client '(Kyc), customer information program, and ant i-money laundering (AML) procedures violated the CFTC rules. [12] According to the complaint, the company accepted at least 85., 000 US customers with more than $ 11 billion assets, intentionally involved in marketing and transactions for US customers. Furthermore, the complaint is to encourage US customers to use VPNs by US customers, for example, to hide the location of customers, or to train US customers to register offshore companies to trade with BitMex. He argues that it intentionally avoided US regulations.

The European Commission's measures ultimately have made a decision on companies and founders. This decision prevents Americans trading on the BitMex trading platform, as well as the $ 100 million individuals who are responsible for the company in involved. In fact, there was a wide range of relief measures aimed at dismantling the US business function of BitMex. These cases were at the beginning, two years ago, when the first bitcoin futures contract were listed on major exchanges. As the digital asset derivative market mature, the execution activities of the European Commission have been mature. In recent years, the European Commission has filed a larg e-scale exchange litigation on digital asset derivatives.

A remarkable example is a revolutionary lawsuit against Bitmex and three founders in 2021. The European Commission, who acted in parallel with criminal authorities, illegally operates a digital asset derivative trading platform, and "knows the customer" (KYC) Program and Money Laundering Procedure (AML) procedure (AML). Instead of implementing, he filed a lawsuit for violating the CFTC rules and violating the regulations of the Product Exchange Law and the European Commission. The client '(Kyc), customer information program, and ant i-money laundering (AML) procedures violated the CFTC rules. [12] According to the complaint, the company accepted at least 85., 000 US customers with more than $ 11 billion assets, intentionally involved in marketing and transactions for US customers. Furthermore, the complaint is to encourage US customers to use VPNs by US customers, for example, to hide the location of customers, or to train US customers to register offshore companies to trade with BitMex. He argues that it intentionally avoided US regulations.

The European Commission's measures ultimately have made a decision on companies and founders. This decision prevents Americans trading on the BitMex trading platform, as well as the $ 100 million individuals who are responsible for the company in involved. In fact, there was a wide range of relief measures aimed at dismantling the US business function of BitMex.

Recently, the European Commission has filed a complaint to the three Binance companies, the CEO of the Binance (CEO), and the Binance's first executive officer (COO). [14] According to the complaint, Binance has illegally invited US traders to make digital assets derivative. Furthermore, in the complaint, since 2017, Binance has a public suspicion of "blocking or restricting" access to buyer s-based buyers platforms. It uses a rationalized strategy to increase the number of individuals, claiming that Binance has not been registered as a designated contract market, swap execution center or futures fee agent in CFTC. The first prosecution that did not follow the CFTC order that prohibits intentional avoidance of the Federal Product Law is currently under dispute.

In the case I explained, I talked about centralized exchanges, especially companies that generally undertake the maintenance of buyers' digital assets in connection with the transactions in question. However, it has a completely different risk of releasing yourself from an intermediate contractor who pretends to be a custodian and trying to make a transaction without being involved in three parties to protect the assets. There is an area of. This is a distributed money and is often called "Defi". The Defi protocol is a smart contract set on a blockchain, reproducing the classic product derivatives and spot market in a seemingly unauthorized outfit. These Defi protocols provide digital asset derivative transactions. In many cases, this transaction is provided on the platform registered in CFTC and must be compliant with the necessary core fundamentals for the purpose of protecting the buyer, and meet the necessary KYC and "Know Your Customer" standards. It may be provided only for buyers. < SPAN> The European Commission has recently submitted a complaint to the three Binance companies, the CEO of the Binance (CEO), and the Binance's first executive officer (COO). According to the complaint, Binance has illegally invited US traders to make digital assets derivative. Furthermore, in the complaint, since 2017, Binance has a public suspicion of "blocking or restricting" access to buyer s-based buyers platforms. It uses a rationalized strategy to increase the number of individuals, claiming that Binance has not been registered as a designated contract market, swap execution center or futures fee agent in CFTC. The first prosecution that did not follow the CFTC order that prohibits intentional avoidance of the Federal Product Law is currently under dispute.

In the case I explained, I talked about centralized exchanges, especially companies that generally undertake the maintenance of buyers' digital assets in connection with the transactions in question. However, it has a completely different risk of releasing yourself from an intermediate contractor who pretends to be a custodian and trying to make a transaction without being involved in three parties to protect the assets. There is an area of. This is a distributed money and is often called "Defi". The Defi protocol is a smart contract set on a blockchain, reproducing the classic product derivatives and spot market in a seemingly unauthorized outfit. These Defi protocols provide digital asset derivative transactions. In many cases, this transaction is provided on the platform registered in CFTC and must be compliant with the necessary core fundamentals for the purpose of protecting the buyer, and meet the necessary KYC and "Know Your Customer" standards. It may be provided only for buyers. Recently, the European Commission has filed a complaint to the three Binance companies, the CEO of the Binance (CEO), and the Binance's first executive officer (COO). [14] According to the complaint, Binance has illegally invited US traders to make digital assets derivative. Furthermore, in the complaint, since 2017, Binance has a public suspicion of "blocking or restricting" access to buyer s-based buyers platforms. It uses a rationalized strategy to increase the number of individuals, claiming that Binance has not been registered as a designated contract market, swap execution center or futures fee agent in CFTC. The first prosecution that did not follow the CFTC order that prohibits intentional avoidance of the Federal Product Law is currently under dispute.

In the case I explained, I talked about centralized exchanges, especially companies that generally undertake the maintenance of buyers' digital assets in connection with the transactions in question. However, it has a completely different risk of releasing yourself from an intermediate contractor who pretends to be a custodian and trying to make a transaction without being involved in three parties to protect the assets. There is an area of. This is a distributed money and is often called "Defi". The Defi protocol is a smart contract set on a blockchain, reproducing the classic product derivatives and spot market in a seemingly unauthorized outfit. These Defi protocols provide digital asset derivative transactions. In many cases, this transaction is provided on the platform registered in the CFTC and must be compliant with the necessary core fundamentals for the purpose of protecting buyers, and meet the necessary KYC and "Know Your Customer" standards. It may be provided only for buyers.

The untreated Defi exchanges are trivial dangers for CFTC's regulated markets and buyers supporting them, and we take this issue very seriously. For example, small errors in the smart contract code may be used by villains and are already used. CFTC has urged exchanges to regulate swap transactions from liquidation agencies and data repo jiti, but they are operated by contracts for sellers' assets, risk management, and exchange trading contracts. It is guided by many basic principles related to these issues, such as preventing them from being. These basic principles use it to protect the buyers in the stock market because of the evils facing Defi members. Therefore, we have taken a decisive measure to compete with such no n-registration and industrial operations.

For example, in 2021, CFTC ordered a reconciliation on Polymarket, which provided a binary option agreement for the event (such as the relative prices of Ethereum and the personal victory in elections). 。 CFTC determined that these contracts were deemed to be swaps under the jurisdiction of CFTC, and as a result, they could only be provided on registered exchanges. CFTC ordered Polymarket to pay a civil exchange penalty, suspend operations that do not comply with the CFTC rules and CFTC rules, and suspend subsequent violations. In this way, polyemarkets have observed the basic principles that all derivative markets must be operated within the law, regardless of the technology or legal system used. < SPAN> The untrained DEFI exchanges are trivial dangers for the CFTC's regulated markets and the buyers supporting them, and we take this problem very seriously. For example, small errors in the smart contract code may be used by villains and are already used. CFTC has urged exchanges to regulate swap transactions from liquidation agencies and data repo jiti, but they are operated by contracts for sellers' assets, risk management, and exchange trading contracts. It is guided by many basic principles related to these issues, such as preventing them from being. These basic principles use it to protect the buyers in the stock market because of the evils facing Defi members. Therefore, we have taken a decisive measure to compete with such no n-registration and industrial operations.

For example, in 2021, CFTC ordered a reconciliation on Polymarket, which provided a binary option agreement for the event (such as the relative prices of Ethereum and the personal victory in elections). 。 CFTC determined that these contracts were deemed to be swaps under the jurisdiction of CFTC, and as a result, they could only be provided on registered exchanges. CFTC ordered Polymarket to pay a civil exchange penalty, suspend operations that do not comply with the CFTC rules and CFTC rules, and suspend subsequent violations. In this way, polyemarkets have observed the basic principles that all derivative markets must be operated within the law, regardless of the technology or legal system used. The untreated Defi exchanges are trivial dangers for CFTC's regulated markets and buyers supporting them, and we take this issue very seriously. For example, small errors in the smart contract code may be used by villains and are already used. CFTC has urged exchanges to regulate swap transactions from liquidation agencies and data repo jiti, but they are operated by contracts for sellers' assets, risk management, and exchange trading contracts. It is guided by many basic principles related to these issues, such as preventing them from being. These basic principles use it to protect the buyers in the stock market because of the evils facing Defi members. Therefore, we have taken a decisive measure to compete with such no n-registration and industrial operations.

For example, in 2021, CFTC ordered a reconciliation on Polymarket, which provided a binary option contract for an exchange binary option agreement based on the event (the relative prices of Ethereum and personal victory in elections). 。 CFTC determined that these contracts were deemed to be swaps under the jurisdiction of CFTC, and as a result, they could only be provided on registered exchanges. CFTC ordered Polymarket to pay a civil exchange penalty, suspend operations that do not comply with the CFTC rules and CFTC rules, and suspend subsequent violations. In this way, polyemarkets have observed the basic principles that all derivative markets must be operated within the law, regardless of the technology or legal system used.

The Ooki DAO case is another important example of the CFTC's crackdown in the DeFi space and the disturbing trend of creating technical or other schemes to structure companies in patent attempts to circumvent regulators' requirements. In this case, the founders of the LLC, the precursor to the DAO, built a profitable trading platform that allowed users to trade retail commodities anywhere in the world with leverage and margin. As mentioned above, only regulated exchanges can offer such trading to the majority of people. However, the founders seemed to consider their platform illegal, claiming that KYC or AML checks were not one of its features, even though know-your-customer was essential to the business. The founders then transferred control of the trading protocol from the LLC to the DAO, making it a decentralized autonomous organization controlled by certain token holders that controlled all of the usual business matters (such as how to sell the protocol and what interest rates to offer) that were determined by the LLC structure. The founders made their purpose clear when they established the DAO: In response, we entered a settlement order against the founders of the DAO and its predecessor LLC, and filed a complaint against the DAO itself.[16] The CFTC subsequently won a precedent-setting lawsuit against the DAO, finding that the CFTC may sue and serve the DAO, that the DAO is subject to the Commodity Exchange Act, and that the DAO violated the law.[17] Thus, for those advising clients, this case makes clear that the DAO's structure does not put anyone above the law.

As I said, last week we have expanded these initiatives and announced three claims as part of the tests of companies engaged in Defi. As part of the first company, Deridex created a distributed exchange with the ability to trade the endless treatie s-the price is exposed to the accidental rate of two digital assets. Derivative of economic products without a period. Similarly, OPYN created a platform established on a blockchain for trading digital assets, enabling digital assets trading on the credit shoulder. And ZEROEX, Inc. came up with distributed exchanges so that users could trade digital assets at once using many tokens in credit shoulders. The three platforms each proposed and confirmed the ove r-th e-line trading with credit shoulders and the marginal transactions with retail products, and also trained other tasks that had been achieved but have achieved. In cooperation with these orders, the platform agreed to complete the illegal nuances of their own work and pay a civil currency fine.

All of this is an obligation to comply with the law, whether CFTC makes an innovative claim to DEFI and provides major derivatives based on digital assets, whether it is centralized or distributed. It tells you that you are defending the proposition. And, as we have established for Polymarket, Daik i-do, OPYN, DIDEX and ZEROEX, we need to be traded with digital assets on a derivative regulated exchange. Create everything with the power of this exchange. Next, I would like to define the necessary and inevitable interests of the law execution department.

universe

The victory in the digital assets spot market is to protect the unity in the derivative market. < SPAN> As I said, last week we have expanded these initiatives and announced three claims as part of a company testing company. As part of the first company, Deridex created a distributed exchange with the ability to trade the endless treatie s-the price is exposed to the accidental rate of two digital assets. Derivative of economic products without a period. Similarly, OPYN created a platform established on a blockchain for trading digital assets, enabling digital assets trading on the credit shoulder. And ZEROEX, Inc. came up with distributed exchanges so that users could trade digital assets at once using many tokens in credit shoulders. The three platforms each proposed and confirmed the ove r-th e-line trading with credit shoulders and the marginal transactions with retail products, and also trained other tasks that had been achieved but have achieved. In cooperation with these orders, the platform agreed to complete the illegal nuances of their own work and pay a civil currency fine.

All this is said to be an obligation to comply with the law, whether CFTC makes an innovative claim to DEFI and provides major derivatives based on digital assets, whether it is centralized or distributed. It tells you that you are defending the proposition. And, as we have established for Polymarket, Daik i-do, OPYN, DIDEX and ZEROEX, we need to be traded with digital assets on a derivative regulated exchange. Create everything with the power of this exchange. Next, I would like to define the necessary and inevitable interests of the law execution department.

universe

The victory in the digital assets spot market is to protect the unity in the derivative market. As I said, last week we have expanded these initiatives and announced three claims as part of the tests of companies engaged in Defi. As part of the first company, Deridex created a distributed exchange with the ability to trade the endless treatie s-the price is exposed to the accidental rate of two digital assets. Derivative of economic products without a period. Similarly, OPYN created a platform established on a blockchain for trading digital assets, enabling digital assets trading on the credit shoulder. And ZEROEX, Inc. came up with distributed exchanges so that users could trade digital assets at once using many tokens in credit shoulders. The three platforms each proposed and confirmed the ove r-th e-line trading with credit shoulders and the marginal transactions with retail products, and also trained other tasks that had been achieved but have achieved. In cooperation with these orders, the platform agreed to complete the illegal nuances of their own work and pay a civil currency fine.

All of this is an obligation to comply with the law, whether CFTC makes an innovative claim to DEFI and provides major derivatives based on digital assets, whether it is centralized or distributed. It tells you that you are defending the proposition. And, as we have established for Polymarket, Daik i-do, OPYN, DIDEX and ZEROEX, we need to be traded with digital assets on a derivative regulated exchange. Create everything with the power of this exchange. Next, I would like to define the necessary and inevitable interests of the law execution department.

universe

The victory in the digital assets spot market is to protect the unity in the derivative market.

From small fraud to billions of fraud, the committee still had a familiar case against Zhulikov. For example, the committee filed a lawsuit against other people related to FTX, ALAMEDA, SAM BANKMAN-FRIDA, and FTX. Raided. As we acknowledge, he illegally received more than 120 million digital assets by exchanging digital assets by manipulating the market. [20] This summer, he filed a lawsuit against Alexander Machinsky and Celsius Network, accusing fraud related to the work of digital asse t-based funding programs and defendants in important implementation. Here are these examples.

Probably the most wel l-known thing we still have a wrong, misleading report on coinbase and Tether to pay 65 million dollars to "washing" transactions. [22], who started successful cases using the legal enforcement capacity in the spot market, and Tether was a false display that the actual measured USD T-currencies are completely equipped with US Bucks. [23] He was instructed to pay a fine of $ 41 million.

To be clear, our law in this field is limited. CFTC does not provide options to adjust the spinal cord market of digital assets. Our options in the actual market are limited to scams and operations. CFTC has such abilities because the derivative bazaar works well because it is based on the Win-Win birth bazaar at its foundation. And the issues we can think of in the spot market are related to the integrity of retail traders and the derivative market for digital assets. However, as our chairman discovered, there is an obvious gap in adjusting the scoop market for digital assets that are not considered to be securities, and as a result, we save this gap and provide CFT C-helping skills for this task. It is necessary to enact the law to be given [24].

What I am trying to do is the derivative market. Endless roads have been implemented since the CFTC product exchange law was enacted. We regulate financial products that are unimaginable, which are now derivatives of digital assets. The technology in this field is still changing vaguely and has revealed new skills for those who try to make a detour of our adaptation system.