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ARTICLE · 12 MARCH 2019

CFTC Releases Enforcement Advisory Regarding Self Reporting And Cooperation For CEA Violations Involving Foreign Corrupt Practices

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On March 6, 2019, the Commodity Futures Trading Commission's Division of Enforcement released an Enforcement Advisory on self-reporting and cooperation for violations of the CEA involving foreign corrupt practices.

United StatesCriminal Law
Paul M. Architzel
Paul M. Architzel
Petal Walker
Petal Walker
Seth Davis
Seth Davis
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On March 6, 2019, the Commodity Futures Trading Commission's (Commission) Division of Enforcement (Division) released an Enforcement Advisory (Advisory) on self-reporting and cooperation for violations of the Commodity Exchange Act (CEA) involving foreign corrupt practices.1

Who does the Advisory apply to?

The Advisory applies to companies and individuals who are not registered (nor required to be registered) with the Commission who choose to cooperate with the Commission.

According to the Advisory, what are the benefits of cooperation for these companies?

The Advisory expands on the Commission's cooperation policies2 by making clear that where these companies and individuals timely self-report violations of the CEA involving foreign corrupt practices, cooperate fully and take appropriate remedial actions, the Division will apply a presumption that it will not recommend a civil monetary penalty.3

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