This month the CFTC laid the groundwork for its injection into anti-corruption enforcement actions with a US$95M settlement with Swiss energy firm Vitol(and with other joint briber investigations between the CFTC and DOJ in the pipeline).

The agency used an anti-manipulation rule introduced as a result of the Dodd Frank Act and modeled after securities laws prohibiting insider trading as the basis for its action.  It was this rule that served as the basis for the CFTC's civil cases against several banks in connection with LIBOR manipulation.

Vitol was alleged to have bribed officials at Brazil's national oil company for inside market intelligence such as reports on production volumes and estimated future imports.

While this settlement relies on traditional anti-manipulation authority, it is noteworthy in its creative use of such authority to regulate corrupt conduct outside the United States.

Corporations should take note that the DOJ and SEC aren't the only regulators who will be waging a war against - and leveling hefty fines in connection with - corrupt conduct,