potential misconduct.This Final Guidance represents the definitive interpretation of how the CFTC will exercise its statutory authority over the listing of VCC derivatives on CFTC-regulated exchanges. The Final Guidance will lead to a higher degree of diligence, transparency and rigor in physical VCC markets overall and may help prevent potential misconduct, including greenwashing. The fact that the CFTC issued the Final Guidance prior to the presidential election shows that the CFTC is prioritizing carbon markets comprised of robust, high-quality VCCs and their derivatives while an administration with similar goals is in office.The authors, along with other members of Holland & Knight's Greenwashing Mitigation Team, are well suited to provide advice regarding the Final Guidance, in addition to other CFTC regulatory matters and advice regarding carbon markets generally.Notes Commission Guidance Regarding the Listing of Voluntary Carbon Credit Derivative Contracts; Request for Comment, 88 Fed. Reg. 89410, Dec. 27, 2023. "CFTC Approves Final Guidance Regarding the Listing of Voluntary Carbon Credit Derivative Contracts," Release No. 8969-24, Sept. 20, 2024. Final Guidance at 9. These include the NYMEX CBL Global Emissions Offset (GEO) futures contract, the NYMEX CBL Nature‑Based Global Emissions Offset (N-GEO) futures contract and the NYMEX CBL Core Global Emission Offset (C-GEO) futures contract. See CBL Global Emissions Offset. For example, the NYMEX CBL GEO futures contract provides delivery of physical carbon offsets that meet standards set by the Carbon Offsetting and Reduction Scheme for International Aviation and the CBL Standard Instruments Program. See NYMEX Rulebook, Chapter 1269, CBL Global Emissions Offset Futures. See Holland & Knight's previous alerts, "CFTC Moves to Set Voluntary Carbon Market Standards," Dec. 13, 2023; "Double Jeopardy for Double Counting? CFTC and FTC Both Scrutinize Fraud in Carbon Markets," Aug. 14, 2023; "FTC Proposes to Clarify Green Guides for Cli