In 2017, under the leadership of new Chairman J. Christopher Giancarlo, the Commodity Futures Trading Commission (CFTC or Commission) adopted a notable shift in its enforcement priorities and regulatory agenda. In March, shortly following his nomination by President Donald Trump as chairman, Chairman Giancarlo signaled that it was time for the CFTC to “reinterpret its regulatory mission” by focusing on fostering economic growth, enhancing U.S. financial markets, and “right-sizing” its regulatory footprint. In particular, he announced Project KISS (“Keep It Simple, Stupid”)—an agency-wide review of rules, regulations, and practices to make them “simpler, less burdensome and less costly.” With respect to enforcement, he emphasized that, under his leadership, “[t]here will be no pause, let up or reduction in our duty to enforce the law and punish wrongdoing in our derivatives markets,” and promised that those who cheat or manipulate markets “will face aggressive and assertive enforcement action by the CFTC under the Trump Administration.”