The U.S. Commodity Futures Trading Commission (CFTC) has granted no-action relief to Gemini Titan, Gemini Olympus, and their participants regarding swap reporting and recordkeeping requirements. At the same time, the agency named Raagnee Beri as the new director of its Whistleblower Office.
According to the CFTC's Division of Market Oversight and Division of Clearing and Risk, staff will not recommend enforcement actions for specific failures tied to swap data reporting and recordkeeping. The relief applies to Gemini Titan, a designated contract market, and Gemini Olympus, a derivatives clearing organization, as well as their participants.
The no-action letter covers contracts with binary and variable payout structures executed through Titan and cleared by Olympus. It supplements earlier guidance under Letter 25-44. The relief is conditional—firms must comply with the terms outlined in the letter to qualify for protection.
The CFTC continues to use no-action letters to address technical compliance challenges, providing temporary relief while rules evolve or systems adjust. Earlier this year, the agency granted Phantom Technologies relief from broker registration requirements in March, and in February, allowed certain commodity pool operators to bypass registration under specific conditions. Additional reporting relief for ownership data and large trader obligations has also been extended.
New Leadership for Whistleblower Office
Raagnee Beri takes the helm of the Whistleblower Office. Chair Mike Selig noted the office supports enforcement through reporting incentives and protections. Beri previously served as a trial attorney in the Division of Enforcement and later as senior assistant general counsel in the litigation branch. General Counsel Tyler Badgley said her experience in enforcement and whistleblower litigation strengthens the office's role.Before joining the CFTC, Beri worked at the Department of Justice Tax Division and clerked in federal and local courts after law school.

