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CFTC Paying for a Company's Dirty Laundry: New Whistleblower Initiatives and Rewards Suggest Increased Enforcement in the Virtual Currency, Foreign Corrupt Practices, Insider Trading, and BSA Spaces

September 24, 2019

By Michael L. Spafford, Nathaniel Edmonds & Daren F. Stanaway

The Commodity Futures Trading Commission (“CFTC”) recently issued a series of four whistleblower alerts aimed at seeking information from would-be whistleblowers in the areas of virtual currency fraud, foreign corrupt practices, insider trading, and violations of the Bank Secrecy Act (“BSA”). These alerts suggest that the CFTC seeks to further incentivize whistleblower cooperation—particularly in areas typically policed by the Financial Crimes Enforcement Network (“FinCEN”) and the U.S. Department of Justice (“DOJ”)—consistent with the CFTC’s previously stated intent to focus its investigative resources on foreign corruption and increasingly active enforcement activity in the virtual currency space.

  • The alerts signal increased CFTC enforcement in the cryptocurrency, foreign corrupt practices, insider trading, and BSA areas.

  • Companies should implement policies and procedures to encourage employees to proactively report issues internally.

  • Commodities market participants should examine compliance programs to assess their potential exposure.

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