Generally, CFTC enforcement proceedings are subject to a five-year statute of limitations under 28 U.S.C. Section 2462. However, there are exceptions. When facing a CFTC investigation, it is imperative to have a clear understanding of all potential allegations, and to formulate a defense strategy that adequately addresses each individual issue that has the potential to lead to enforcement action. This involves conducting a comprehensive internal compliance audit promptly (and with the oversight of outside counsel) upon learning of a CFTC inquiry.