The CFTC encourages targeted firms and individuals to cooperate during its investigations, stating that it “has long given credit to individuals who cooperate in the Commission’s investigations and enforcement actions.” However, while cooperating can prove beneficial in some cases, it can also be risky if the circumstances do not favor a cooperative approach. Additionally, firms and individuals that cooperate in CFTC investigations will often find themselves facing increasingly burdensome requests—with failure to comply putting the benefits of their prior cooperation at risk. As a result, deciding whether to cooperate involves several strategic considerations, and it is a decision to be made case-by-case with the advice of CFTC investigation defense counsel.