In the Latest Wells Fargo Prime Service’s “Industry and Regulatory Update,” Asset Management Attorneys Provide Insights on CFTC Actions Against Elephas

Asset management partner, and derivatives and commodities practice head Deborah Monson and asset management associate Jeremy Liabo co-authored an article that discusses recent enforcement actions by the United States Commodity Futures Trading Commission and the Chicago Board of Trade against non-U.S. fund manager Elephas Investment Management Limited for violating speculative position limits. The piece was published in the September 2019 edition of Wells Fargo Prime Service’s “Industry and Regulatory Update.”

The piece discusses how actions against Elephas highlight the traps for unwary asset managers and other market participants who trade products subject to position limits. In the article, Ms. Monson and Mr. Liabo provide a list of key considerations that asset managers should take into account when designing their position limits compliance program,  regardless of whether they are in the U.S. or not, and regardless of whether they are registered with the CFTC or not.