Partner Michelle Tanney, Counsel Isabelle Corbett Sterling and Associate Shelleah Jackson contributed an article to The Journal of Federal Agency Action titled “Commodity Futures Trading Commission Announces New System to Incentivize Self-Reporting, Cooperation and Remediation.” Published in the July-August 2025 issue, the article is an overview of the enforcement advisory, introducing the metrics the Department of Enforcement will use to evaluate conduct before and leading up to the discovery of a potential violation of the Commodity Exchange Act. It will also discuss things to be considered when contemplating a self-report.
