The Commodity Futures Trading Commission (CFTC) on Thursday issued guidance to companies on how it will evaluate compliance programs in connection with enforcement matters.
The three-page guidance, much shorter than the Department of Justice’s well-known “Evaluation of Corporate Compliance Programs,” recommends CFTC staff consider whether a company being investigated for misconduct has a compliance program that was reasonably designed to prevent and detect the misconduct at issue, as well as the steps the program took to remediate the identified misconduct.
