The CFTC recently settled with a non-registered energy merchant that violated the CFTC’s ‘aggregate position limits’ rulemaking. The CFTC order filing and settling these charges was the first of its kind enforcing aggregate position limits. The CFTC also recently finalized guidance on listing derivatives on voluntary carbon credits (VCC).

Why this matters:

• Any company with traders who trade on CFTC-licensed exchanges must understand the aggregate position limits requirements;
• The guidance on VCC derivatives applies directly to CFTC-registered exchanges but will likely also affect the standards used by market participants in spot VCC markets. 
• Companies should consider whether their policies and procedures reflect these recent CFTC developments.