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On August 3, 2021, Securities and Exchange Commission (“SEC”) Chair Gary Gensler made headlines when he dubbed the current cryptocurrency landscape the “Wild West.”

Unlike the year most of us have had, FY2020 was a banner year for the Commodities Futures Trading Commission’s (“CFTC” or the “Commission”) Division of Enforcement. According to the Division of Enforcement’s Annual Report, which was released on December 1, 2020, the CFTC broke multiple records this fiscal year.

On October 8, 2020, the Attorney General’s Cyber-Digital Task Force (“the Task Force”) issued its Cryptocurrency Enforcement Framework (the “Report”), which offers background on virtual assets, enforcement milestones, and plans for increasing scrutiny into the use of cryptocurrency, following the Task Force’s inception in 2018.

On September 10, 2020, the Commodity Futures Trading Commission (“CFTC”) Division of Enforcement released its long-awaited “Guidance on Evaluating Compliance Programs in Connection with Enforcement Matters,” which will be incorporated into the CFTC’s enforcement manual and used by CFTC enforcement staff when reviewing the efficacy of corporate compliance programs moving forward.