Overview
Steptoe partner Matt Kulkin, associate Ayana Dow, and legislative assistant Carisa McLaney co-authored a paper, "The Role of Internal Controls in Facilitating Swap Deal Compliance with Commodity Futures Trading Commission Regulations," for the Futures Industry Association's Law & Compliance Conference held April 27-29, 2022. The paper analyzes the expectations set by Congress in adopting the Dodd-Frank Act, the CFTC in promulgating its regulations for swap dealers with respect to internal controls in order to facilitate compliance, as well as 2021 CFTC swap dealer enforcement cases where controls' failures were significant factors in alleged instances of noncompliance. The paper concludes with several recommendations to support SD efforts to strengthen internal controls and ensure appropriate supervision.
