Page 33 - 期货和衍生品行业监管动态（2026年2月）

期货和衍生品行业监管动态

“insider trading”) pursuant to Section 6(c)(1) of the Act, and Regulation

180.1(a)(1) and (3).

While Kalshi’s internal enforcement program handled these matters, under the

Act, the Commission has full authority to police illegal trading practices occurring on

any DCM, including those described above related to prediction markets. Without

limitation, these practices include:

 Misappropriation of confidential information in breach of a pre-existing duty

of trust and confidence to the source of the information (commonly known as

“insider trading”) pursuant to Section 6(c)(1) of the Act, and Regulation

180.1(a)(1) and (3); see, e.g., CFTC v. Clark,Civil Action No. 4:22-cv-00365

(S.D. Tex., Jan. 29, 2026 consent order); In re Webb, et al., CFTC Docket No.

21-09 (June 14, 2021 admin. order).

 Pre-arranged, noncompetitive trading and wash sales, under Section 4c(a)(1)
and (2)(A) of the Act, and Regulation 1.38(a); see, e.g., In re Khorrami, et al.,

CFTC Docket No. 20-15 (May 7, 2020 admin. order); CFTC v. Singhal, et al.,

Civil Action No. 1:12-cv-00138 (N.D. Ill., Nov. 28, 2012 consent order).

 Other prohibited trading practices including disruptive trading pursuant to

Section 4c(a)(5); see, e.g., In re Mirae Asset Daewoo Co. Ltd. , CFTC

Docket No. 20-11 (Jan. 13, 2020 admin. order).

 Fraud and manipulation under various sections of the Act; see, e.g., In re

Dairy Farmers of America, Inc., et al., CFTC Docket No. 09-02 (Dec. 16,

2008 admin. order).

DCMs have an independent duty pursuant to the core principles of the Act to

maintain audit trails, conduct surveillance, and enforce rules against prohibited

practices. See Section 5(d) of the Act (Core Principles for Contract Markets). In

appropriate cases, the Division will investigate and prosecute violations, as it always

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