# CFTC replaces its enforcement cooperation policy with a defined path to declination

> The CFTC Division of Enforcement replaced all prior cooperation advisories, including the February 2025 matrix-based self-reporting, cooperation and remediation policy.

- URL: https://riadefi.com/regulation/2026-05-19-cftc-enforcement-cooperation-policy-lifecycle/
- Posture: Guidance
- Authorities: U.S. Commodity Futures Trading Commission
- Event date: 2026-05-19
- Effective: 2026-05-19
- Version: 1, published 2026-08-07 (first published 2026-08-07)
- Advisor-relevant: yes

## What changed

The CFTC Division of Enforcement replaced all prior cooperation advisories, including the February 2025 matrix-based self-reporting, cooperation and remediation policy. The May 2026 policy describes a potential declination path, absent aggravating circumstances, for voluntary self-reporting, full cooperation, timely remediation, and full restitution or disgorgement, and specifies cooperation credit when declination is unavailable.

## Who it affects

- CFTC registrants and registered entities
- Commodity pool operators, commodity trading advisors, futures commission merchants and swap firms
- Investment advisers and funds with CFTC-regulated affiliates or activity
- Counsel handling internal investigations and CFTC disclosures

## What is still open

- How the Division will apply aggravating circumstances and cooperation-credit levels in individual matters
- How referrals and parallel agency or criminal investigations will affect declination decisions

## What it means for an advisor

- Replace references to the 2025 matrix and referral framework with Staff Advisory 26-15; require counsel-led analysis before self-reporting and preserve evidence of timing, cooperation, remediation, restitution and disgorgement.

## Previous interpretation

The February 2025 advisory used a first-ever mitigation-credit matrix, supplemented in April 2025 by operating-division referral criteria. Staff Advisory 26-15 expressly superseded prior cooperation advisories in May 2026.

## Sources

1. [CFTC replaces its enforcement cooperation policy with a defined path to declination](https://www.cftc.gov/PressRoom/PressReleases/9054-25) · U.S. Commodity Futures Trading Commission · 2025-02-25
2. [CFTC replaces its enforcement cooperation policy with a defined path to declination](https://www.cftc.gov/csl/25-13/download) · U.S. Commodity Futures Trading Commission · 2025-04-17
3. [CFTC replaces its enforcement cooperation policy with a defined path to declination](https://www.cftc.gov/PressRoom/SpeechesTestimony/johnsonstatement022525) · U.S. Commodity Futures Trading Commission · 2025-02-25
4. [CFTC replaces its enforcement cooperation policy with a defined path to declination](https://www.cftc.gov/PressRoom/PressReleases/9234-26) · U.S. Commodity Futures Trading Commission · 2026-05-19 · effective 2026-05-19
5. [CFTC replaces its enforcement cooperation policy with a defined path to declination](https://www.cftc.gov/csl/26-15/download) · U.S. Commodity Futures Trading Commission · 2026-05-19 · effective 2026-05-19
6. [CFTC replaces its enforcement cooperation policy with a defined path to declination](https://www.cftc.gov/PressRoom/SpeechesTestimony/opamiller1) · U.S. Commodity Futures Trading Commission · 2026-03-31


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