Atlanta Economics Club Keynote Address At The Federal Reserve Bank of Atlanta by Commissioner Kristin N. Johnson
Policing the (Token) Economy: Introducing Corporate Governance and Market Structure Reforms in Crypto and Environmental Commodities Markets
November 13, 2023
Thank you to the Federal Reserve Bank of Atlanta and the Atlanta Economics Club (AEC) for the kind invitation to join you today. In many ways, being with you feels like a homecoming. Immediately prior to my nomination by President Biden to serve in my current role as a Commissioner of the Commodity Futures Trading Commission (CFTC or Commission), I served as a tenured faculty member and Associate Dean at Emory University Law School.
I am thankful for an opportunity to spend time here in the vibrant city of Atlanta with you and Raphael Bostic, President and Chief Executive Officer (CEO) of the Federal Reserve Bank of Atlanta, and the exceptionally capable staff here, including immediate Past-President of the AEC, Jessica Dill.
I am inspired by your valuable thought leadership on critical issues in global and domestic monetary policy and your commitment to enhance the growth and development of the regional and national economy.
An anticipated disclaimer—my remarks reflect my own views, but I am hopeful that some of my reflections will shape the important dialogue at the Commission regarding the future of our markets.
During my time this afternoon, I would like to underscore the significance, potential, and concerns arising in the emerging market for two asset classes: the crypto or digital asset markets and environmental commodities markets. In the coming weeks, I believe that the Commission will take important first steps introducing market structure reforms in both of these markets. These critical reforms will establish customer property protections in non-intermediated clearing markets (a reform that is increasingly important as market participants seek to adopt this approach to offer leveraged, crypto-products to retail investors) and long-awaited guidance on voluntary carbon markets.
Upon hearing the title of my remarks, Policing the (Token) Economy: Introducing Corporate Governance and Market Structure Reforms in Crypto and Environmental Commodities Markets, one might query as to whether crypto and environmental commodities share any common ground. Others may note the novelty of each asset class, while some may offer sharp criticisms of misconduct in the market for each of these asset classes.
Each of the two asset classes at the center of my remarks today has captured the spotlight in global financial markets. And, as I noted in a recent speech at Rice University’s Baker Institute for Public Policy Annual Energy Summit, a small cadre of market participants are attempting to marry these novel financial products and offer tokenized carbon credits.
Indisputably, and quite frequently discussed in the media, a market survey reveals pernicious fraud and related misconduct in each asset class. To begin to address these issues the CFTC has launched a digital assets fraud task force and an environmental commodities fraud task force. While policing the emerging markets for these novel asset classes is critical, enforcement reflects only part of the CFTC mandate.
Reflecting on deep concerns regarding misconduct in each of the markets reveals a clear and urgent need to introduce long-standing and widely-adopted corporate governance and market structure reforms.
I have continuously advocated for corporate governance reforms and greater transparency in digital asset markets including ensuring the appointment of a majority independent board of directors, effective internal controls, audited financial statements, an independent auditor, and rigorous examinations of systems safeguards to mitigate operational risks such as cyber threats, and foundational customer protections such as segregation of customer assets or separation of member property mandates.
We must begin to introduce a regulatory framework that will ensure the integrity of the markets for any asset class that comes within our jurisdiction.
Among other reforms, this framework should, create greater transparency through effective transaction reporting; offer guidance that applies the core principles of CFTC regulation to secondary market trading intermediaries such as exchanges or clearing houses; offer guidance regarding accountability standards for intermediaries to ensure integrity and reliability; outline business conduct standards including introducing a standardized methodology for valuation and documentation (for environmental commodities this may include certification); and, as applicable, introduce appropriate guardrails including disclosure based on the investor demographics for each market.
To ensure integrity in environmental commodities markets, we may need further reforms, including, among others, the creation of carefully developed registries; mitigation of vulnerabilities, such as double-counting, greenwashing, or the risk of leakage; and the introduction of a rigorous standard for demonstrating additionality and permanence.
Let’s Begin at the Beginning—Bitcoin and the Rising Threat of Climate-Related Risks
In the innocuously titled white paper - Bitcoin: A Peer to Peer Electronic Cash System—an author writing under the pseudonym Satoshi Nakamoto unveiled a digital currency supported by a distributed network that verified peer-to-peer transactions with network timestamps, eliminating the need for financial services firms to serve as intermediaries verifying available funds and mitigating the risk of double-spending.
Similarly, responding to escalating and more frequent severe weather events and other climate risks that increasing threaten the global economy, voluntary and compliance markets began to offer intangible credits for projects seek to limit greenhouse gas (GHG) emissions into the atmosphere as well as projects that sequester carbon such as reforestation projects that remove atmospheric carbon. Colloquially, many refer to these environmental commodities as carbon offsets.
In digital asset and carbon offset markets, we find:
- intangible commodities that are readily tradable;
- spot markets that are not comprehensively regulated;
- enforcement jurisdiction permitting anti-fraud and market manipulation authority over spot markets; and
- exclusive jurisdiction to create regulation for derivatives transactions for which crypto or environmental commodities are the underlying assets.
Let’s quickly set the table before turning to potential regulatory interventions.
Alongside the undeniable growth in each asset class (some might argue exponential growth of crypto-markets prior to the onset of the crypto winter in 2022), markets have witnessed historic and headline capturing fraud. Whether it is classic, garden-variety fraud or something more pernicious, in digital asset and carbon credit markets, misconduct threatens to undermine the public trust and confidence, market integrity, and the benefits that each innovative market may engender.
As I will describe shortly, the CFTC is expressly authorized by Congress to exercise broad anti-fraud and anti-manipulation authority in policing commodity derivatives and commodity spot markets.
Effectively exercising this authority reduces transaction costs, enables price discovery, and enhances price accuracy, among other benefits. But ex post enforcement is not enough.
Using each market as a case study, let’s consider the potential and limitations that we observe in each asset class; certain common challenges; and timely action plans that may help to mitigate misconduct risk and enhance market participants’ ability to manage credit, market, and operational risks. Each of these risk management goals would improve the integrity of markets and prioritize core principles underlying our regulatory goals such as enhancing customer protection and fostering market stability.
I’ll conclude by offering an immediately adoptable plan of action for both crypto and carbon markets that introduces traditional market structure reforms that are currently underdeveloped or altogether missing in crypto and carbon offset markets.
The Commodity Exchange Act establishes the authority of the Commission to surveil and enforce regulation in commodity derivatives and spot markets as well as adopt and implement regulation governing commodity derivatives markets.
Over the last several years, the CFTC Division of Enforcement has announced actions in several of the most important investigations and civil enforcement actions in crypto-markets.
Year-Over-Year Enforcement Review
Over the last year, the CFTC announced 96 enforcement actions, a total number of enforcement actions that is nearly 20% higher than the total number of enforcement actions announced the previous fiscal year. The categories of cases announced include: 1) manipulative conduct, false reporting, spoofing; 2) supervision, financial integrity, and business conduct; 3) system safeguards, reporting, and other regulatory violations by registered entities; 4) illegal off-exchange contracts; 5) failure to register; 6) trade practice violations (including wash trades, fictitious trades, and violations of position limits); 7) reporting and recordkeeping violations; 8) misappropriation of material, non-public, confidential information; 9) statutory disqualification; and 10) fraud.
This brings us to an important observation regarding the data. Markets have witnessed a remarkable rise in fraud enforcement cases involving digital assets.
This year represents a high watermark for the total number of crypto-fraud enforcement actions announced by the Commission. During the last fiscal year, nearly 44 of the 59 fraud enforcement actions announced involved transactions in digital asset markets. The total number of crypto-fraud cases initiated by the Commission nearly doubled year over year since last year as well.
Concerningly, this increase suggests that the total number of crypto-fraud cases initiated by the Commission is roughly five times higher than what it was just three years ago. This demonstrates the shocking speed with which participants are entering the market for this asset class as well as how quickly some are identifying ways to exploit investors in the market.
Significant Crypto Cases
Reflecting on the allegations in several of the most significant crypto cases announced by the Commission during the most recent fiscal year reveals governance, regulatory, and market structure challenges in crypto markets. The lack of transparency and visibility into the crypto-spot market enables illicit activity, undermines the integrity of the market, and stymies the development of innovative projects based on the underlying technology which demonstrates potential to engender economic or social benefits.
In December of 2022, in coordination with the Department of Justice (DOJ), U.S. Attorney’s Office for the Southern District of New York (SDNY) and the Securities and Exchange Commission (SEC), the CFTC charged Sam Bankman-Fried, FTX Trading Ltd. d/b/a/ FTX.com (FTX) and Alameda Research LLC (Alameda) with fraud and material misrepresentations in connection with the sale of digital commodities in interstate commerce.
The complaint alleges that from May 2019 to November 11, 2022, Mr. Bankman-Fried controlled both FTX.com, a centralized digital asset derivative platform, and Alameda, a digital asset trading firm that operated as a primary market maker on FTX.
FTX held itself out as “the safest and easiest way to buy and sell crypto.” In other words, tapping into the fear of missing out (FOMO) that has characterized certain crypto-investor demographics, Mr. Bankman Fried and FTX solicited customers on the premise that the FTX platform could be trusted and represented the highest quality standards.
Most importantly, FTX promised that customers would control access to the assets in their accounts, had control over those assets at all times, and that those assets were “appropriately safeguarded and segregated” from FTX’s own funds.
The complaint alleges that despite these promises FTX permitted Alameda to access customer deposits and commingle customer assets with Alameda’s proprietary funds. The complaint further alleges that Alameda and executives at FTX used these funds for its own business operations, personal purchases, acquisitions of other businesses, and for risky investments.
In other words, while soliciting customers to trust in the integrity of its business, FTX is alleged to have engaged in the very business practices that it denounced. The complaint alleges that defendants’ actions caused the loss of over $8 billion in customer deposits.
In March of 2023, the Commission announced a civil enforcement action against three affiliated operating entities constituting the digital asset exchange Binance, the CEO of Binance Changpeng Zhao (CZ), and the former chief compliance officer of Binance Samuel Lim. At the time, Binance described itself as the world’s largest centralized digital asset exchange.
According to the complaint, Binance offered and executed digital asset spot and derivative transactions for U.S. customers. The CFTC complaint alleges that, based on the transactions executed on its platforms, the CEA and CFTC regulations required Binance to register with the Commission and submit to standard regulatory requirements imposed on firms providing similar trade execution, clearing, and settlement services.
The complaint also alleges that Binance engaged in a campaign to intentionally avoid being subject to regulation. According to Binance, the global firm was not headquartered in any jurisdiction and did not permit trading by U.S. persons. The Commission alleges that Binance strategically obscured the location of their customers in an effort to assert that the platform had no U.S. customers, and alleges that any Binance compliance program merely served as window-dressing. Binance intentionally solicited U.S. customers and offered these customers guidance on how to evade the company’s sham compliance controls.
Binance never registered with the CFTC and disregarded Bank Secrecy Act and anti-terrorism financing know your customer (KYC) and anti-money laundering (AML) obligations. Corporate compliance functions, KYC, and AML regulations have long stood in the way of bad actors’ attempted use of the traditional financial system, yet Binance is alleged to have intentionally avoided such essential safeguards.
Last summer, the CFTC announced an enforcement action against Celsius alleging that the company operated as an unregistered commodity pool operator in violation of CFTC regulations requiring registration.
The Commission has alleged that Celsius, and its CEO Alexander Mashinsky, engaged in a scheme to defraud hundreds of thousands of customers by misrepresenting the safety and profitability of its digital asset-based finance platform. Mashinsky and Celsius, in numerous public media appearances, reiterated the safety of the Celsius platform for customers’ digital asset commodities.
Customers deposited funds and anticipated exceptionally high returns. Based on promises that customer capital was well-preserved and that deposits would earn exceptionally high returns, Celsius was able to attract approximately $20 billion of customer deposits.
To achieve these high returns, Celsius pooled customer’s assets and loaned the assets through the Celsius Pool - a platform that never registered as a commodity pool operator with the Commission.
Instead of reinvesting customer assets in “safe” investments, Mashinsky and Celsius pursued riskier and risker trades, all the while reassuring the public and customers that Celsius had the ability to satisfy requests for immediate redemptions or withdrawals. A month after delivering this reassurance, Celsius froze customer withdrawals and, within weeks, filed for bankruptcy protection.
Last month, in a coordinated action with the Federal Trade Commission (FTC), the CFTC announced an enforcement action against Stephen Ehrlich, the former CEO of Voyager, a digital asset platform. The complaint in the enforcement action alleges that the platform engaged in fraud and failed to register as a commodity pool operator as required under the CEA and CFTC regulations. Voyager falsely touted the Voyager platform as a “safe haven” to earn high-yield returns to induce customers to purchase and store digital asset commodities.
As I stated in my remarks when the Commission announced it had brought this action, “contrary to that marketed image, Voyager and Ehrlich are alleged to have approved loans valued at hundreds of millions of dollars of customer assets to numerous third parties that, for example, made prominent disclaimers that investing with them had a high degree of risk that could result in investors losing all their money.”
Voyager is alleged to have conducted insufficient due diligence on the investments. When one of the counterparties defaulted on repaying a Voyager loan of roughly $650 million of customer assets, Ehrlich concealed the firm’s precarious financial position, failing to acknowledge the exposure created by the default. Ehrlich continued soliciting deposits from new and existing customers. Voyager then distributed incoming customer deposits to longer-term customers who sought to withdraw their funds.
Voyager later filed for bankruptcy protection. As I noted in my statement: “It is astounding that Voyager failed to exert pressure on the firms where it invested its customers’ assets. Instead of demanding that investment firms that received customer assets offer greater levels of transparency, Voyager shirked the long-established expectations for custodians and simply dispatched customer assets with little effort to preserve the same.”
This survey leads to several notable observations regarding recent crypto-fraud or failure to register cases.
First, all but one of the firms that the CFTC announced enforcement actions against are currently seeking bankruptcy protection in U.S. bankruptcy courts. This outcome is deeply unfortunate for the many customers and creditors who may never receive full restitution in connection with their deposits and investments in these firms.
Second, in multiple instances, transparency—or rather the lack of transparency or visibility into the business operations and risk management practices—amplified customer losses and market disruption.
Finally, in several instances, a CEO, with unbridled authority (an imperial CEO some might say) operated without the effective checks and balances provided by traditional and long-adopted corporate governance measures such as a majority independent board of directors, internal controls, audited financial statements, an independent auditor, and the extensive examinations of systems safeguards and segregation of customer deposits.
The CFTC has immediately within its authority several tools to begin to address this lack of transparency as well as readily available remedies that may address the lack of customer protections, and introduce broader market reforms in necessary corners of crypto markets.
Before turning to these remedies, allow me to say a few words about the second case study that I will cover in my remarks, the market for environmental commodities.
Over the last several years, the global economy has navigated persistent inflation alongside other challenging macroeconomic conditions. The challenges presented by the onset of the COVID-19 pandemic and geopolitical events have deeply impacted energy and grain markets and introduced further stress. Our markets have demonstrated remarkable resilience, yet much work remains.
A report by the U.S. Department of the Treasury released in September explains that “[t]he impacts of climate change are significant and escalating, including through more frequent and severe weather events, rising sea levels, and higher temperatures.” The report details how climate-risks are impacting individual household finances, U.S. financial markets, and supply chains. “In 2022 alone, the cost of climate and weather disasters in the United States totaled more than $176 billion – the third most costly year on record.”
A recent United Nations IPCC Synthesis Report indicates that “[h]uman activities, principally through emissions of greenhouse gases, have unequivocally” caused an increase in the global surface temperature over the last century. “Global greenhouse gas emissions have continued to increase, with unequal historical and ongoing contributions arising from unsustainable energy use, land use and land-use change, lifestyles and patterns of consumption and production across regions, between and within countries, and among individuals.
Climate Risks and Financial Markets
For over a decade, we have recognized the increasing risks that severe climate events create in markets and for critical market participants. In 2012, Superstorm Sandy flooded a vault of the Depository Trust and Clearing Corporation. The flood damaged or destroyed 1.7 million stock and bond certificates, as well as millions of other documents.
Just last year, the lowest water levels in the Mississippi River in a decade, caused by a severe Midwest drought, closed the vital channel to barge traffic, deeply impacting transportation logistics including distribution of crops from the nation’s heartland.
In recent visits with the farming and manufacturing communities in the Midwest, I learned first-hand of the persistent challenges that these communities are facing. The Mississippi River has continued to experience historically low levels due to drought. Barges were grounding on sandbars in unprecedented numbers and many ports and docks no longer had water deep enough for commercial boats to safely reach them. With fewer boats and barges able to transport goods, prices, during certain periods, skyrocketed. The Army Corps of Engineers has worked diligently to enhance shipping along the Mississippi River, but the volumes transported along the river continue to remain much lower than historic or desired levels.
It’s not only local transport and logistics that may be impacted by too little or too much rainfall or other severe weather conditions. Indisputably, global markets and global supply chains are also being impacted by drought.
In March, I visited with the agricultural communities in Kenya in East Africa and in Ghana in West Africa to discuss the state of the markets in these important food production and distribution centers in the global economy. In meetings with the then-Governor of the Central Bank of Kenya, I listened to the descriptions of the challenges that emerging economies that rely heavily on agricultural production are experiencing as they navigate severe climate conditions.
Traveling to Central and South America, for over a century, the Panama Canal has provided a convenient way for ships to move between the Pacific and Atlantic Oceans, helping to expedite and reduce the costs of international trade. Similar to the drought effects hindering transport along the Mississippi River Valley, insufficient water levels are impacting the flow of transport through the Panama Canal, resulting in shipping delays and increased costs.
Further the recent U.S. Treasury report illustrates the strain that climate events place on U.S. household finances. Thirteen percent of Americans reported economic hardship from disasters or severe weather events in the past year. Climate-related disasters have caused “widespread physical damage and force interruptions and closures of normal operations of businesses, governments, and other critical services. As a result, households could face significant financial strain from lost employment due to job loss, from reduced working hours, or from interruptions in access to income supports or other public benefits. Adding to these challenges, climate hazards make it more costly and difficult for households to access a range of consumer goods and services.”
For its part, the CFTC has engaged in three significant steps to address climate-related risks that may affect the functioning of markets essential for economic activity.
First, the CFTC recognizes the need to begin to examine the scope and impact of climate-related risks on our markets. In 2020, the Climate-Related Financial Risks Subcommittee of the Market Risk Advisory Committee published a report examining the impact of climate risks including potential for liquidations and disruptions of financial market utilities.
As the report noted, “a combination of slow-onset and sudden extreme weather events in major agricultural states … could lead to high volatility in certain agricultural commodity prices. Commodity prices can become especially volatile when storage facilities are damaged or storage capacity is otherwise constrained, forcing contracting parties supplying the physical commodity to incur additional costs. High volatility, in turn, could result in calls for variation-margin payments to clearinghouses and to greater pressure on short-term funding markets to fund large payouts related to the same extreme weather events. The result could be a liquidity crunch that temporarily interferes with the smooth functioning of the commodity futures market.”
A more recent report echoes these findings. The Board of Governors of the Federal Reserve System, the Federal Deposit Insurance Corporation, and the Office of the Comptroller of the Currency recently issued joint guidance and offered principles that provide a high-level framework for the safe and sound management of exposures to climate-related financial risks for large financial institutions.
The guidance emphasized “[f]inancial institutions are likely to be affected by both the physical risks and transition risks associated with climate change (collectively, climate-related financial risks). Weaknesses in how financial institutions identify, measure, monitor, and control climate-related financial risks could adversely affect financial institutions’ safety and soundness.”
Second, the Commission has hosted two convenings focused on the market for carbon offsets. Following the first voluntary carbon market convening, the Commission solicited comments from the public regarding how the Commission may effectively respond to emerging concerns.
Third, and this is the primary focus of my remarks today, the Commission must initiate effective enforcement, offer guidance, and refine existing regulation in carbon credit markets.
CFTC Guidance for Carbon Credit Markets
According to a recently announced IOSCO consultation:
“Voluntary markets are markets where entities buy carbon credits to offset some or all of their own carbon emissions. These carbon credits are issued in relation to climate change mitigation projects, either through carbon removals and through emissions reductions – for example, by investing in renewable energy or planting trees.”
There are over two hundred derivatives of such environmental commodities contracts currently traded on CFTC-regulated exchanges in the United States. It is imperative that the Commission ensure the integrity of the underlying assets of contracts trading in our markets.
Maintaining Integrity in Carbon Offset Markets
Last fall, U.S. Senators Elizabeth Warren, Cory Booker, and Kirsten Gillibrand alongside several other Senators, encouraged the CFTC to use its enforcement jurisdiction aggressively to investigate and prosecute fraud and manipulation in spot and forward environmental commodity markets.
According to the Senators' letter, “[s]everal studies have highlighted that carbon offset projects are frequently illegitimate, and those that do contribute to meaningful emissions reductions are often representative of broader ‘pay to pollute’ schemes that place profit over protecting frontline communities.” The letter future urges “the CFTC should take concrete steps to implement rules governing the carbon market” and encourages the Commission to adopt rules governing carbon credit markets that “include a clear definition of a carbon credit and a robust standard for auditing.” The letter further acknowledges the need to “take into account the environmental justice risk of growth in the offset market.”
Allow me to offer the following thoughts in conclusion.
While the markets for crypto and carbon offsets are novel and notwithstanding the fact that each reflects the potential for emerging technology to empower important opportunities and engender significant benefits, early evidence regarding opportunistic exploitation and fraud in these markets reveals two things.
First, there is nothing new under the sun. The novelty of the technology underlying each of these asset classes demonstrates valuable potential, but without proper governance and market reforms, fraudsters will seek to benefit from the obscurity of these markets and the complexity inherent in creating, distributing, monitoring, tracking, and trading these assets.
Second, we must take immediate action to introduce necessary corporate governance and market reforms. The CFTC’s “mandate includes an obligation to guard against illicit activity and ensure market integrity and market stability to advance the safety and soundness of derivatives markets.” A clear and comprehensive regulatory framework is a prerequisite to ensuring market integrity and fostering the stability of the domestic and global economy.
And, finally, while Congressional action may be helpful to introduce a comprehensive, whole-of-government solution, many valuable tools for policing and introducing market structure for crypto and carbon offset markets are immediately within the Commission’s remit.
The FTX, Binance, Celsius, and Voyager cases illustrate the significant need to protect customers by segregating and preserving customer deposits in all markets subject to our oversight. I am advocating that the Commission begin to immediately develop regulation to directly address custody-centered and other market structure concerns.
There are certain principles that must guide the development of market structure for each of these novel asset classes including the introduction of transaction reporting; secondary market regulation including, where relevant, clearing and settlement guidance; accountability standards for intermediaries to ensure integrity and reliability (and in the context of environmental commodities additionality); business conduct standards, including standardized documentation (and requirements for certification of environmental commodities); and appropriate guardrails for any retail market participation.
Similar to our leadership in bringing critical enforcement actions, the CFTC must lead in issuing advisories, guidance, and begin developing rule makings that introduce transparency and market structure reforms in crypto and environmental commodities markets.
Thank you so much for allowing me to share these reflections today.
 Kristin Johnson, Commissioner, Commodity Futures Trading Commission (CFTC), Keynote Address at Rice University’s Baker Institute for Public Policy Annual Energy Summit, Credibility, Integrity, Visibility: The CFTC’s Role in the Oversight of Carbon Offset Markets (Oct. 5, 2023), https://www.cftc.gov/PressRoom/SpeechesTestimony/opajohnson7.
 The Integrity Council for the Voluntary Carbon Market, Core Carbon Principles, Assessment Framework and Assessment Procedure: Terms and Definitions 2 (2022), https://icvcm.org/wp-content/uploads/2022/07/ICVCM-Public-Consultation-FINAL-Part-5.pdf (“A tradable financial instrument that is issued by a carbon-crediting program. A carbon credit represents a greenhouse gas emission reduction to, or removal from, the atmosphere equivalent to one metric tonne of carbon dioxide equivalent, calculated as the difference in emissions from a baseline scenario to a project scenario. Carbon credits are uniquely serialized, issued, tracked and retired or administratively cancelled by means of an electronic registry operated by an administrative body, such as a carbon-crediting program.”).
 7 U.S.C. § 9(1); 17 C.F.R. § 180.1(a) (2022).
 7 U.S.C. § 2(a).
 Press Release No. 8822-23, CFTC, CFTC Releases FY 2023 Enforcement Results (Nov. 7, 2023), https://www.cftc.gov/PressRoom/PressReleases/8822-23.
 Press Release No. 8638-22, CFTC, CFTC Charges Sam Bankman-Fried, FTX Trading and Alameda with Fraud and Material Misrepresentations (Dec. 13, 2022), https://www.cftc.gov/PressRoom/PressReleases/8638-22; Kristin N. Johnson, Commissioner, CFTC, Statement on Preserving Trust and Preventing the Erosion of Customer Protection Regulation (Nov. 3, 2023), https://www.cftc.gov/PressRoom/SpeechesTestimony/johnstatement110323.
 See Commodity Futures Trading Commission v. Samuel Bankman-Fried, FTX Trading Ltd d/b/a FTX.com, and Alameda Research LLC (S.D.N.Y. 2022) (Compl.).
 See Commodity Futures Trading Commission v. Changpeng Zhao, Binance Holdings Limited, Binance Holdings (IE) Limited, Binance (Services) Holdings Limited, and Samuel Lim (N.D. Ill. 2023) (Compl.).
 See Complaint, Commodity Futures Trading Comm’n v. Changpeng Zhao, Binance Holdings Ltd., Binance Holdings (IE) Ltd., Binance (Services) Holdings Ltd. & Samuel Lim, 1:23-CV-01887 (N.D. Ill. Mar. 27, 2023), enfbinancecomplaint032723.pdf.
 See Commodity Futures Trading Commission v. Celsius Network, LLC and Alexander Mashinsky (S.D.N.Y. 2023) (Compl.).
 Press Release No. 8749-23, CFTC, CFTC Charges Alexander Mashinsky and Celsius Network, LLC with Fraud and Material Misrepresentations in Massive Commodity Pool Scheme Involving Digital Asset Commodities (July 13, 2023), https://www.cftc.gov/PressRoom/PressReleases/8749-23; Kristin N. Johnson, Commissioner, CFTC, Statement: Taking Action to Prevent Fraud By Digital Asset Services Firms (July 13, 2023), https://www.cftc.gov/PressRoom/SpeechesTestimony/johnsonstatement071323.
 Press Release No. 8805-23, CFTC, CFTC Charges Former Chief Executive Officer of Digital Asset Platform with Fraud in Massive Commodity Pool Scheme (Oct. 12, 2023), https://www.cftc.gov/PressRoom/PressReleases/8805-23; Kristin N. Johnson, Commissioner, CFTC, Statement Regarding CFTC Charges Against Voyager Chief Executive Officer (Oct. 12, 2023), https://www.cftc.gov/PressRoom/SpeechesTestimony/johnsonstatement101223.
 Kristin N. Johnson, Commissioner, CFTC, Statement Regarding CFTC Charges Against Voyager Chief Executive Officer (Oct. 12, 2023), https://www.cftc.gov/PressRoom/SpeechesTestimony/johnsonstatement101223.
 U.S. Dep’t of the Treasury, The Impact of Climate Change on American Household Finances 1 (2023), https://home.treasury.gov/system/files/136/Climate_Change_Household_Finances.pdf.
 Headline Statements of AR6 Synthesis Report, Intergovernmental Panel on Climate Change, https://www.ipcc.ch/report/ar6/syr/resources/spm-headline-statements.
 Halle Parker, The Mississippi River is Again Experiencing Historically Low Levels Due to Drought, NPR, https://www.npr.org/2023/11/01/1209857323/the-mississippi-river-is-again-experiencing-historically-low-levels-due-to-droug.
 Peter Eavis, Drought Saps the Panama Canal, Disrupting Global Trade, N.Y. Times (Nov. 1, 2023), https://www.nytimes.com/2023/11/01/business/economy/panama-canal-drought-shipping.html.
 U.S. Dep’t of the Treasury, supra, at 15.
 Id. (“As in New Orleans following Hurricane Katrina, repair costs may cause some households to abandon owned housing due to declining property values or repair expenses surpassing the property’s worth. Property abandonment can reduce household assets and impair their ability to build wealth through homeownership.”); David Uberti, U.S. Drought Threatens to Prop Up Food Inflation, Wall St. J. (June 30, 2023, 11:00 AM), https://www.wsj.com/articles/u-s-drought-threatens-to-prop-up-food-inflation-5c39fc87 (“Food costs were finally starting to show signs of easing after the pandemic and Russia’s invasion of Ukraine sent prices skyrocketing. Now, a drought across America’s breadbasket is a threat to further relief.”).
 Commodity Futures Trading Comm’n, Managing Climate Risk in the U.S. Financial System (2020), https://www.cftc.gov/sites/default/files/2020-09/9-9-20%20Report%20of%20the%20Subcommittee%20on%20Climate-Related%20Market%20Risk%20-%20Managing%20Climate%20Risk%20in%20the%20U.S.%20Financial%20System%20for%20posting.pdf.
 Id. at 29.
 Principles for Climate-Related Financial Risk Management for Large Financial Institutions 1 (2023), https://www.govinfo.gov/content/pkg/FR-2023-10-30/pdf/2023-23844.pdf.
 Int’l Org. of Sec. Comm’n, Voluntary Carbon Markets, CR/06/22 at 5 (2022) https://comments.cftc.gov/Handlers/PdfHandler.ashx?id=34819.
 Letter from Cory A. Booker, et al., U.S. Senators, to Rostin Behnam, Chairman, CFTC (Oct. 13, 2022.
 Kristin N. Johnson, Commissioner, CFTC, Keynote Address at Digital Assets @ Duke Conference, Duke’s Pratt School of Engineering and Duke Financial Economics Center (Jan. 26, 2023), https://www.cftc.gov/PressRoom/SpeechesTestimony/opajohnson2.