To read this content please select one of the options below:

CFTC enters the market for anti-corruption enforcement

Journal of Investment Compliance

ISSN: 1528-5812

Article publication date: 23 September 2019

Issue publication date: 16 October 2019




This paper aims to analyze the March 6, 2019 enforcement advisory in which the Division of Enforcement (Division) of the US Commodity Futures Trading Commission (CFTC or Commission) announced that it will work alongside the US Department of Justice (DOJ) and other agencies to investigate foreign bribery and corruption relating to commodities markets.


This paper explains the enforcement advisory and outlines key considerations for industry participants and their compliance teams, including the CFTC’s plan to investigate in parallel with other enforcement authorities, an expansion of the CFTC’s existing self-reporting, cooperation and remediation policy to address foreign corruption and the CFTC’s focus on market and economic integrity, and provides guidelines for commodities companies concerning anti-corruption compliance and training programs, investigating potential incidents of bribery and corruption, reporting obligations under the Commodity Exchange Act (CEA) and CFTC regulations, voluntary reporting of incidents of foreign corruption and whistleblowing.


The CFTC announcement adds a new dimension to an already crowded and complex landscape for anti-corruption enforcement. A range of industries, including energy, agriculture, metals, financial services, cryptocurrencies and beyond, must now consider the CFTC and the CEA when assessing global compliance and enforcement risks relating to bribery and corruption.


Expert guidance from lawyers with broad experience in white collar defense, investigations, financial services, securities, commodities, energy and derivatives.



Fisher, A.S., Yatter, D.K., Greenburg, D.N., Baker III, W.R., Dozier, B.A. and Greenberg, R.J. (2019), "CFTC enters the market for anti-corruption enforcement", Journal of Investment Compliance, Vol. 20 No. 3, pp. 32-38.



Emerald Publishing Limited

Copyright © 2019, Latham & Watkins LLP.

Related articles