News & Analysis as of

Self-Reporting Commodities Futures Trading Commission New Guidance

Morrison & Foerster LLP

CFTC Advisory Outlines Materiality Criteria for Enforcement Referrals

On April 17, 2025, three operating divisions (the “Operating Divisions”) of the U.S. Commodity Futures Trading Commission (“CFTC”) and the Division of Enforcement (“DOE”) provided guidance in CFTC Letter 25-13 (the...more

BakerHostetler

CFTC Provides Clarifying Guidance on Material Violations Regarding Self-Reporting, Cooperation, and Remediation System

BakerHostetler on

As we previously reported, in February, the CFTC’s DOE issued an enforcement advisory (the DOE Advisory) to provide guidance to market participants on how the DOE will evaluate a company’s or an individual’s conduct in the...more

Jones Day

CFTC Operating and Enforcement Divisions Issue Advisory on Referrals to Enforcement Division

Jones Day on

On April 17, 2025, the Commodity Futures Trading Commission's ("CFTC") operating divisions ("Divisions") provided guidance in an advisory on the criteria they will use when determining whether to refer self-reported...more

Morgan Lewis

CFTC Staff Issue Advisory on Criteria for Referrals to the Division of Enforcement

Morgan Lewis on

The staff of the US Commodity Futures Trading Commission (CFTC or Commission) on April 17, 2025 issued an advisory outlining the criteria the agency’s Market Participants Division, Division of Clearing and Risk, and Division...more

Husch Blackwell LLP

CFTC Releases Criteria for Operating Divisions to Refer Violations to Enforcement Division

Husch Blackwell LLP on

On April 17, 2025, the Commodity Futures Trading Commission’s (CFTC) Market Participants Division (MPD), the Division of Clearing and Risk (DCR), and the Division of Market Oversight (DMO)—collectively the Operating...more

Davis Wright Tremaine LLP

CFTC Divisions Issue Staff Advisory on Referrals to Division of Enforcement

On April 17, 2025, the Market Participants Division, the Division of Clearing and Risk, and the Division of Market Oversight (collectively, the "Operating Divisions") of the CFTC, along with the Division of Enforcement...more

Skadden, Arps, Slate, Meagher & Flom LLP

CFTC Issues Advisory on Referrals to the Division of Enforcement

On April 17, 2025, three operating divisions of the Commodity Futures Trading Commission (CFTC) jointly issued an advisory to provide guidance on the materiality or other criteria they will use in deciding whether to make a...more

Ogletree, Deakins, Nash, Smoak & Stewart,...

CFTC Unveils Replacement Penalty Mitigation Policy Focused on Self-Reporting, Cooperation, and Remediation

The Commodity Futures Trading Commission (CFTC), an independent U.S. government agency that regulates the U.S. derivatives markets, including futures, options, and swaps, has announced a new policy for mitigating potential...more

Baker Botts L.L.P.

CFTC Issues Enforcement Advisory Adopting New Approach for Consideration of Self-Reporting, Cooperation, and Remediation

Baker Botts L.L.P. on

On February 25th, the Commodity Futures Trading Commission (CFTC or Commission) adopted a new approach for how the Division of Enforcement (Division) will assess self-reporting, cooperation, and remediation efforts when...more

Skadden, Arps, Slate, Meagher & Flom LLP

CFTC Issues New Enforcement Guidance on Cooperation Recognition in Its Orders

On October 29, 2020, the Commodity Futures Trading Commission (CFTC) Division of Enforcement (Division) issued a memorandum (Guidance) providing guidance for Division staff to follow when recommending the recognition of an...more

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