The Commodity Futures Trading Commission has issued a staff advisory setting out the Division of Enforcement’s new policy on cooperation, replacing all prior advisories on the subject. The policy creates a route to a potential declination, absent aggravating circumstances, for respondents that voluntarily self-report, fully cooperate, undertake timely and appropriate remediation, and provide full restitution and or disgorgement. The advisory also explains how the division will evaluate cooperation and self-reporting and what level of cooperation credit may be available when a respondent does not qualify for a declination. The CFTC presented the update as a simplified and more transparent framework intended to clarify the requirements for obtaining credit in enforcement matters involving insider trading, fraud, manipulation, and other market abuse.