Commodity Exchange Act

Second Circuit Again Limits Extraterritorial Reach of Commodity Exchange Act

In Laydon v. Co√∂peratieve Rabobank U.A., the Second Circuit once again held that the Commodity Exchange Act (CEA) does not apply to futures contracts traded on U.S. exchanges that are tied to the values of foreign commodities. Although the transactions in this case undoubtedly occurred in the United States, the court held that the claims…

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District Court Interprets Geographic Scope of the Commodity Exchange Act

In a recent decision, CFTC v. WorldWideMarkets Ltd., the federal district court for the District of New Jersey (Judge Kevin McNulty) interpreted the geographic scope of the Commodity Exchange Act (CEA), holding that two of its provisions apply only when irrevocable liability for a transaction is incurred within the United States. The decision aligns the…

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