On February 25, 2025, the Commodity Futures Trading Commission (CFTC) released an Enforcement Advisory (The Advisory) outlining concrete guidelines for self-reporting, cooperation, and remediation. The Advisory provides explicit guidance to companies and individuals on how to receive credits against civil penalties by self-reporting and cooperating with Commission investigations.

President Trump has issued a series of executive orders targeting the private sector’s initiatives related to Diversity, Equity, and Inclusion (DEI) and/or Diversity, Equity, Inclusion, and Accessibility. As DEI-related disclosures will likely be scrutinized more closely, it is critical for companies to evaluate the risks of their DEI programs and proactively mitigate the risk of investor claims that may arise from their pursuit of—or withdrawal from—DEI initiatives and their associated public statements.President Trump has issued a series of executive orders targeting the private sector’s initiatives related to Diversity, Equity, and Inclusion (DEI) and/or Diversity, Equity, Inclusion, and Accessibility. As DEI-related disclosures will likely be scrutinized more closely, it is critical for companies to evaluate the risks of their DEI programs and proactively mitigate the risk of investor claims that may arise from their pursuit of—or withdrawal from—DEI initiatives and their associated public statements.