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ARTICLE · 17 MAY 2019

CFTC Signals Foreign Corrupt Practices Investigations

Skadden, Arps, Slate, Meagher & Flom LLP
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On March 6, 2019, the Commodity Futures Trading Commission's (CFTC or Commission) Division of Enforcement (Division) published an advisory on self-reporting and cooperation for violations of the Commodity Exchange Act.

United KingdomFinance and Banking
David Meister
David Meister
Jonathan Marcus
Jonathan Marcus
Theodore M. Kneller
Theodore M. Kneller
Daniel B. O'Connell
Daniel B. O'Connell
Chad Silverman
Chad Silverman

On March 6, 2019, the Commodity Futures Trading Commission's (CFTC or Commission) Division of Enforcement (Division) published an advisory on self-reporting and cooperation for violations of the Commodity Exchange Act (CEA) that involve foreign corrupt practices. On the same date, James McDonald, the CFTC's enforcement director, announced the new advisory at the American Bar Association's National Institute on White Collar Crime conference. In issuing the advisory, the Division signaled for the first time its intention to investigate and charge CEA and CFTC rule violations related to foreign corrupt practices.

The advisory applies to companies and individuals who are not registered or required to be registered with the CFTC, who "timely and voluntarily" disclose to the Division CEA violations "involving" foreign corrupt practices and follow up the disclosure with full cooperation and appropriate remediation. If a firm or individual meets these criteria, the Division

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