When a Foreign Corruption Case Is Not a Foreign Corruption Case

Earlier this month, the U.S. Commodity Futures Trading Commission (CFTC) brought what it billed as a “historic enforcement action . . . tied to foreign corruption” against Vitol, Inc., a U.S.-based commodities trading firm doing business under the Vitol Group global corporate umbrella. The press release accompanying the settlement also cited the CFTC’s March 6, 2019, advisory on self-reporting violations of the Commodity Exchange Act (CEA) “involving foreign corrupt practices.”