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ARTICLE · 02 APRIL 2019

No Stone Unturned? The CFTC Targets Foreign Corrupt Practices Involving Commodity Interests

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US Commodity Futures Trading Commission ("CFTC") Division of Enforcement ("DOE") Director James McDonald announced on March 6 that the agency would more closely partner with law enforcement

United StatesFinance and Banking
Matthew F. Kluchenek
Matthew F. Kluchenek
Daniel Stein
Daniel Stein
Laurence Urgenson
Laurence Urgenson
Steven Wolowitz
Steven Wolowitz
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US Commodity Futures Trading Commission ("CFTC") Division of Enforcement ("DOE") Director James McDonald announced on March 6 that the agency would more closely partner with law enforcement and, for the first time, bring its own actions related to foreign corrupt practices. The Foreign Corrupt Practice Act ("FCPA"), enacted in 1977, generally prohibits payment of bribes to foreign officials to assist with obtaining or retaining business.1 The CFTC also released an advisory on self-reporting and cooperation for Commodity Exchange Act ("CEA") violations involving the FCPA (the "FCPA Advisory").2 To date, the CFTC has not brought any enforcement actions based on violations of the FCPA, and this appears to be a foray into new territory for the DOE.

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