CFTC Commissioner Pham Encourages Self-reporting on Compliance Issues

CFTC Commissioner Caroline D. Pham encouraged firms to establish a compliance program to "identify, escalate, and self-report material or potentially material non-compliance issues to the relevant authorities."

In remarks at the NYU Law Program on Corporate Compliance and Enforcement Fall Conference, Ms. Pham said that self-reporting potential compliance issues is not only required by law, but it helps to remediate misconduct prior to CFTC intervention. The result is generally more favorable settlement terms, and the degree of reduction in a penalty depends on the level of cooperation.

Ms. Pham encouraged firms to report potential compliance issues to the proper authorities through a supervisor or compliance officer, legal counsel, HR office or anonymous hotline and said that being proactive and transparent will help build good standing with the CFTC.