The Department of Justice ("DOJ") and the Commodity Futures Trading Commission ("CFTC") in recent years have worked closely together to target companies and individuals for violations of the Commodity Exchange Act and other laws. As former senior officials at the DOJ and the CFTC, we expect the agencies to double down on this joint initiative in the years ahead, continuing to pursue commodities fraud cases with even greater focus and intensity. Accordingly, companies active in the commodities and derivatives markets should understand how these agencies work together and their enforcement priorities.

This White Paper addresses these issues and offers practical tips for companies to take stock of their compliance programs. Armed with this information, companies can ensure that they are prepared to deal with the potential for robust civil and criminal commodities fraud enforcement by the DOJ and the CFTC in the years ahead.