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ARTICLE · 27 OCTOBER 2026

CFTC Issues New Enforcement Policy On Cooperation

A&O Shearman
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The Commodity Futures Trading Commission has introduced a comprehensive enforcement policy that fundamentally reshapes how the agency evaluates cooperation from market participants and registrants. This new framework establishes clear pathways for entities to secure declinations from enforcement actions or receive substantial penalty reductions through voluntary self-reporting, full cooperation, timely remediation, and complete restitution.

United StatesCorporate/Commercial Law
A&O Shearman
A&O Shearman
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On May 19, 2026, the Commodity Futures Trading Commission (“CFTC”) published a staff advisory letter to the Division of Enforcement which outlined a new policy for evaluating a party’s cooperation with the agency and superseded prior policies. CFTC Letter No. 26-151 (“Letter”) describes the Division’s approach to cooperation when pursuing potential violations of the Commodity Exchange Act (“CEA”) and CFTC Regulations. The policy is effective immediately and aims to provide clear definitions and clarity with respect to how the Division of Enforcement treats Voluntary Self-Reports, Full Cooperation, Timely and Appropriate Remediation, and Full Restitution and/or Disgorgement, and when and how the Division will find a party’s cooperation warrants a declination.

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