In May 2026, the Commodity Futures Trading Commission (CFTC)’s Division of Enforcement (Division) announced a new policy (Policy) regarding cooperation on the part of individuals and organizations that might face an enforcement action. The Policy aims to clarify the Division’s stance on cooperation, taking a more consistent approach and fostering greater understanding of the potential consequences of self-reporting, remediation, restitution and/or disgorgement. This first article in a two-part series summarizes the Policy and its cooperation safe harbors. Part two will compare it to the superseded February 2025 Enforcement Advisory and other agencies’ cooperation policies, assess its potential impact and provide practical takeaways. See “Obligations Linger Despite Freepoint’s Settlements With DOJ and CFTC” (Aug. 28, 2024).