The CFTC’s New Enforcement Manual Guidance Details Factors Used in Corporate Compliance Programs
The Commodity Futures Trading Commission (“CFTC”) has announced Division of Enforcement staff-level guidance that outlines whether a company’s compliance program was reasonably designed and implemented to (i) prevent the underlying misconduct at issue; (ii) detect the misconduct; and (iii) remediate the misconduct. At all points, the Division will conduct a risk-based analysis, taking into consideration