In this episode of S&C’s Critical Insights podcast series, Katy McArthur and Ryne Miller, co-heads of the Firm’s Commodities, Futures & Derivatives Practice, discuss a recent release from the CFTC’s Division of Enforcement that updates guidance on relevant factors it considers when enforcing civil monetary penalties. Ryne and Katy outline the updated guidance and explain the reasons behind the  timing of the release. They also explore the implications of the new guidance for defense counsel and entities under investigations.