Skip to content


Harry Cassin
Publisher and Editor

Andy Spalding
Senior Editor

Jessica Tillipman
Senior Editor

Richard L. Cassin
Editor at Large

Elizabeth K. Spahn
Editor Emeritus

Cody Worthington
Contributing Editor

Julie DiMauro
Contributing Editor

Thomas Fox
Contributing Editor

Marc Alain Bohn
Contributing Editor

Bill Waite
Contributing Editor

Shruti J. Shah
Contributing Editor

Russell A. Stamets
Contributing Editor

Richard Bistrong
Contributing Editor

Eric Carlson
Contributing Editor

Bill Steinman
Contributing Editor

Practice Alert: CFTC will investigate and prosecute FCPA violations

The Commodity Futures Trading Commission (CFTC) said Wednesday it will work alongside of the DOJ and SEC to investigate foreign bribery and prosecute overseas corruption offenses.

In a March 6 Enforcement Advisory (pdf), the CFTC’s Division of Enforcement said commodities companies that self report violations of the Commodity Exchange Act  involving foreign corrupt practices could receive declinations.… Continue Reading

CFTC adopts simpler rules for compliance officers

The Commodity Futures Trading Commission adopted rules that simplify requirements for compliance officers and harmonize the agency’s approach to compliance with the SEC.

The CFTC said Tuesday the amended rules (pdf) “clarify a CCO’s duties by providing reasonable standards and guidance on effective compliance.”

“The amendments also modify the CCO annual report content and submission requirements to reduce report preparation burdens while also making the reports more effective.”

While simplifying the requirements for chief compliance officers, the new rules still require CCOs to be “actively engaged in administering a firm’s compliance policies and procedures.”

The CFTC said the amendments aren’t “intended to diminish the role and direct involvement of other senior officers, supervisors and other employees with more direct knowledge, expertise, and responsibilities for various regulated activities within their business lines.”

“Thus, while the CCO plays a central role in administering a firm’s policies and procedures, other personnel may implement the procedures on a day-to-day basis when undertaking related activities in the normal course of business.”

The agency said the new rules synchronize requirements with the SEC for compliance officers at security-based swap dealers.… Continue Reading

JP Morgan rap sheet is deep and wide

JP Morgan Chase reached a tentative deal with the DOJ this weekend to settle a slew of past transgressions for $13 billion.

No word yet if the FCPA investigation triggered by the bank’s targeted hiring of princelings in China and elsewhere will be included in the settlement.… Continue Reading

Interview with Vincente Martinez of the CFTC Whistleblower Program: Part III

This is Part III of a four-part interview with Vincente Martinez, Director of the CFTC Whistleblower Office (WBO). Click here for Part I and Part II.

*     *     *

As companies adjust to the new whistleblowing regimes under the Dodd-Frank Act, what changes do you recommend that they make to their existing compliance programs to ensure they are adequately prepared to manage whistleblowers and/or CFTC inquiries in response to whistleblower complaints?Continue Reading

Interview with Vincente Martinez of the CFTC Whistleblower Program: Part I

In 2010, the Dodd-Frank Act created whistleblower bounty programs in both the Securities and Exchange Commission (SEC) and the Commodity Futures Trading Commission (CFTC). While readers of this blog are familiar with the SEC’s program because of its impact on FCPA enforcement, they may not be as familiar with the CFTC’s program. 

I recently sat down with Vincente Martinez, Director of the CFTC Whistleblower Office (WBO), who graciously agreed to answer some of my questions about the WBO.… Continue Reading