The CFTC’s Completion of “Enforcement Sprint” Offers Insight Into the New Administration’s Enforcement Approach

On September 4, 2025, the Commodity Futures Trading Commission (CFTC) issued six orders simultaneously filing and settling material compliance-related violations against 10 firms and imposing $8,325,000 in total penalties. These orders marked the completion of the “enforcement sprint” that Acting Chair Caroline Pham announced in March 2025, as well as the first application of the Division of Enforcement’s February 2025 Advisory on Self-Reporting, Cooperation, and Remediation (2025 Advisory).

Key Takeaways:

• Although these resolutions addressed different types of compliance violations, they offer insight into the Enforcement Division’s priorities and approach to enforcement under the new Administration.
• The CFTC is likely to give significant credit for cooperation when determining civil monetary penalties, especially in compliance-related cases.
• When assessing penalties, the CFTC will review and analyze comparable cases from the past decade.
• Enforcement priorities will focus on cases involving fraud, manipulation, and harm to victims, though the CFTC may still address and resolve large-scale compliance matters.