CFTC Enforcement Priorities: What Whistleblowers Need to Know

If you work in financial services, commodities trading, or the digital asset space and have witnessed conduct that doesn't seem right, the Commodity Futures Trading Commission (CFTC) may be very interested in what you know — and may be willing to reward you for coming forward with that information.

The CFTC's whistleblower program has paid out hundreds of millions of dollars to individuals who have brought original information about violations of the Commodity Exchange Act to the agency. But not all tips are created equal. In a March 2026 address at NYU Law School, CFTC Enforcement Director David Miller laid out five specific enforcement priorities for the agency. Understanding them can help you assess whether what you've witnessed could form the basis of a viable whistleblower claim.

1. Insider Trading
   The CFTC is aggressively targeting insider trading across all markets it oversees, with a particular focus on prediction markets. The CFTC is seeking information about individuals who tip or trade with misappropriated information. These people may include traders, corporate executives, sports league employees, and even government officials who trade on non-public government information. Predication markets are of particular interest to the CFTC, and the agency is clear that insider trading laws are equally applicable in that context.
2.  Market Manipulation — Especially in Energy Markets
   Market manipulation is a core enforcement target, and energy markets are the CFTC's sharpest focus. Because energy demand is inelastic and price changes ripple through the broader economy, manipulation in these markets causes uniquely widespread harm. If you have inside knowledge of schemes designed to distort energy prices or other commodity markets, this is a high-priority area for the agency.
3. Market Abuse and Disruptive Trading
   Spoofing, wash trading, and disruptive trading during closing periods remain serious enforcement targets. These practices undermine market integrity by creating false impressions of supply and demand. They are often invisible to outsiders, making insiders at trading firms among the few people positioned to document and report them.
4. Retail Fraud
   The CFTC maintains a dedicated task force targeting fraud aimed at individual investors, including Ponzi schemes, commodity pool fraud, pig-butchering scams, impersonation fraud, and phishing attacks. These schemes increasingly use AI-generated content, fake apps, and social media targeting to prey on the elderly and financially vulnerable. If you work at a firm engaged in any of these practices, the CFTC is actively pursuing these cases.
5. Anti-Money Laundering and Know-Your-Customer Violations
   Willful failures to comply with AML and KYC laws round out the CFTC's five priorities. The agency is not focused on technical or inadvertent violations, it is targeting entities that knowingly disregard these obligations. Given the links between AML failures and terrorism, narcotrafficking, and fraud, the CFTC has signaled it will make criminal referrals in appropriate cases.

What This Means for You
Under the CFTC whistleblower program, eligible individuals can receive between 10% and 30% of sanctions collected when the agency recovers more than $1 million based on original information. The program also provides strong anti-retaliation protections.

If you have observed potential violations in any of these areas, speaking with an experienced whistleblower attorney is the critical first step. An attorney can help you evaluate your information confidentially, protect your rights, and position your submission for maximum impact.