On January 14, 2021 the CFTC published a notice which requires action of all Futures Commission Merchants (FCM), Introducing Brokers (IB and GIB), Commodity Trading Advisors (CTA), and Commodity Pool Operators (CPO).

Registered firms have been instructed by the CFTC to consider the following:

The DHS Cybersecurity and Infrastructure Security Agency (CISA) has issued an alert regarding post-SolarWinds compromise activity by the SolarWinds threat actor that involves Microsoft Azure cloud environments and Office365.  CISA’s notice concerning the alert is copied below.  The alert includes guidance on three open-source tools—including a CISA-developed tool named Sparrow—that can be used to help detect and remediate malicious APT actor activity in this connection.

  1. Do you use Microsoft Azure cloud services and/or Microsoft Office365?  If your answer is no, no response or further action is necessary.  
  2. If your answer is yes to the above, please run CISA’s Sparrow tool, plus other available tools of your choosing as noted in the CISA alert, in order to determine whether you are affected by any compromise of any of your accounts or applications in Microsoft Azure or Office365 environments.
  3. If the Sparrow tool or any other information indicates that you have experienced such a compromise, please telephone one of the persons listed by Close of Business Monday, January 18, 2021.  Barry McCarty at 202-418-6627, or Helene Schroeder at 202-418-5424

Please be advised that firms should document and keep on record evidence they have taken this action per the CFTC request. In particular firms using Azure or Office 365 should document that they have run the Sparrow Tool or other available tools pursuant to the CFTC and CISA alert above. Records should be kept pursuant to the firms record keeping policies as Turnkey believes they may be considered during regulatory examinations in the future.

In the event questions come up with the above obligation please feel free to contact Turnkey for assistance. We can be reached via phone at (312) 324-0040 or via email at info@turnkeytradingpartners.com.

More About Turnkey

Regulated brokerage and trading firms have their work cut out for them in keeping up with the latest compliance obligations. Turnkey Trading Partners is an award winning firm that provides customized support to the brokerage and trading industry. We can assist Commodity Trading Advisors (“CTA”), Commodity Pool Operators (“CPO”), Introducing Brokers (“IB”), and Futures Commission Merchant’s (“FCM’s”) working within the alternative investments space.  Our team is well versed in both operational and regulatory matters relating to commodity futures, equities, bonds, options, swaps, forex, digital currency, cash and physical trading, as well as several other specialized financial markets transaction types. Not a subscriber to our newsletter? You’re missing out! Sign up and request to receive more information here.