On March 6, 2019, the CFTC issued a new Enforcement Advisory, signaling for the first time its intention to become involved in investigations relating to foreign corrupt practices. The announcement suggests a more expansive view of the agency’s enforcement agenda and foretells increased complexity in CFTC and FCPA enforcement matters on a number of fronts, Sullivan & Cromwell partners Kathleen McArthur and Aisling O’Shea argue in this guest article. See “What to Consider When Deciding Whether to Self-Disclose: An Interview With Steptoe’s Lucinda Low” (Apr. 4, 2018).
-
- |
