Entries by Matthew Podolsky

08 05 '26

The First Prediction Market Insider Trading Case: SDNY and CFTC Test the Limits of Fraud and Commodities Law

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On April 23, 2026, the U.S. Attorney’s Office for the Southern District of New York (“SDNY”) and the Commodity Futures Trading Commission (“CFTC”) announced parallel criminal and civil actions against a U.S. Army service member accused of using classified military information about a planned operation to capture Venezuelan President Nicolás Maduro to place profitable trades on Polymarket, a prediction market platform. The case, the first to apply traditional insider trading and fraud theories to prediction markets, signals a shift in how the government will regulate this emerging market.  In response to this news, companies should consider reviewing company policies on insider trading and compliance to address prediction markets and the use of confidential information in connection with event-based trading.

22 04 '26

Evolving AML/CFT Expectations and Enforcement Priorities as FinCEN Releases FY 2025 Year in Review

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On April 16, 2026, the Financial Crimes Enforcement Network (“FinCEN”) released its Year in Review for Fiscal Year 2025 (the “FY 2025 Report”). The report provides a concise overview of recent regulatory and enforcement developments in the financial crimes space and offers insight into FinCEN’s evolving priorities.

FinCEN highlights several key accomplishments over the past year, including reporting $10 billion in savings attributed to deregulatory efforts, enhancing the management and sharing of Bank Secrecy Act (“BSA”) data with law enforcement, and expanding engagement with private-sector stakeholders on anti-money laundering and countering the financing of terrorism (“AML/CFT”) issues.