In March 2019, the CFTC’s then-Enforcement Director surprised many when he said that the CFTC would investigate and bring enforcement actions relating to foreign corrupt practices that impacted that swaps and futures markets. Then, in late 2020, in a coordinated resolution with the Department of Justice, the CFTC brought its first such action, against the commodities trader Vitol, imposing penalties and disgorgement of $95.7 million. In this webinar, we discuss the basis for the CFTC’s anti-corruption efforts to police the integrity of the swaps and futures markets, its coordination with other agencies, and how companies can mitigate the risk of such corruption-related investigations and enforcement actions by maintaining a strong compliance program.
