The new policy (Policy) announced by the Commodity Futures Trading Commission’s Division of Enforcement in May 2026 is designed to incentivize self-reporting and cooperation and to establish a clear path toward declination. However, more guidance is needed to alleviate doubts as to the ultimate benefits of self-reporting, according to legal experts interviewed by the Anti-Corruption Report. In the absence of further clarity, parties should not automatically rush to self-report when they become aware of violations or assume they can easily secure a declination. This second article in our two-part series compares the Policy to the superseded February 2025 Enforcement Advisory and to other agencies’ cooperation policies, assesses its potential impact and provides practical takeaways. The first article summarized the Policy and its cooperation safe harbors. See “Former SEC and CFTC Officials Unpack the 2026 Enforcement Landscape” (Jul. 29, 2026).