Investment advisers should by now be well aware of the SEC’s compliance rule (Rule 206(4)‑7), which requires them to maintain policies and procedures reasonably designed to ensure compliance with relevant securities laws and regulations. A recent CFTC settlement order against Wells Fargo Bank, N.A. (Wells Fargo) is an important reminder that firms subject to the CFTC’s jurisdiction must also be cognizant of the CFTC’s business conduct standards and its analog of the compliance rule – and that the CFTC continues to focus on swaps and derivatives. Wells Fargo, which has been registered with the CFTC as a swap dealer since 2012, entered into a forward currency contract at a price that was to be based on the actual prices of the bank’s spot trades on behalf of the counterparty. Wells Fargo, however, allegedly lacked a system to track those prices and, as a result, provided inaccurate information to its counterparty. This article analyzes the terms of the forward currency contract; the alleged misconduct and violations; and the settlement terms. For discussion of the CFTC business conduct standards, see “A ‘Clear’ Guide to Swaps and to Avoiding Collateral Damage in the World of ERISA and Employee Benefit Plans (Part Two of Four)” (Aug. 4, 2016).