On May 19, 2026, the Commodity Futures Trading Commission (“CFTC” or the “Commission”) Division of Enforcement issued a new staff advisory setting forth a revised policy for evaluating cooperation and self-reporting in enforcement matters (the “CFTC Policy”).1 The CFTC Policy shares structural similarities with — but also differs in important respects from — the Federal Energy Regulatory Commission’s (“FERC”) longstanding Revised Policy Statement on Penalty Guidelines (the “FERC Penalty...