The Commodity Futures Trading Commission updates its Enforcement Manual

Civil Monetary Penalty Guidance On May 28, 2020 James McDonald, Director of Enforcement at the Commodity Futures Trading Commission (CFTC) gave a speech at the Futures Industry Association addressing the issues of penalties and penalty guidance, following up on a memo to staff (see here). This marked the first time in 25 years the CFTC […]

DOJ Compliance Program Guidance

Earlier this year the Department of Justice (DoJ) issued two publications for prosecuting attorneys to provide guidance on assessing the effectiveness of corporate compliance programs. The two publications (April 2019 and July of 2019) further develop and update the “Evaluation of Corporate Compliance Programs,” issued by the Criminal Division’s Fraud Section released in February 2017 […]