- Chief Compliance Officer and VP of Legal Affairs, Arrow Electronics
By 
Kyle Brasseur2022-11-15T16:29:00
Businesses take varying approaches when self-reporting to regulatory agencies, which can lead to differing results regarding cooperation credit. The advice of one commissioner at the Commodity Futures Trading Commission (CFTC): don’t be “too cute.”
Caroline Pham shared her views on self-reporting during remarks delivered at an NYU Law compliance conference Monday. Pham, one of four new commissioners confirmed to join the CFTC in March, repeated the mantra “if you see something, say something,” which she said was “drilled into the sales and trading teams on the trading floors and in other lines of business” by compliance staff during her 7 1/2 years working for Citi.
Of course, saying something to regulators carries extra weight beyond internal reporting. Like other U.S. agencies, the CFTC often rewards cooperation and remediation during its investigations, but each case is judged on its own individual merits.
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