Energy Trading Compliance: FERC Enforcement, Penalties and Impact of CFTC Rules on Energy Transactions

Anti-Manipulation Rules, Self-Reporting, Individual Liability

A live 90-minute CLE webinar with interactive Q&A

Thursday, May 9, 2019

1:00pm-2:30pm EDT, 10:00am-11:30am PDT

Early Registration Discount Deadline, Friday, April 12, 2019

or call 1-800-926-7926

This CLE webinar will guide energy counsel and advisers on recent developments in the Federal Energy Regulatory Commission (FERC)’s enforcement efforts and the impact of the Commodity Futures Trading Commission (CFTC) rules on energy transactions. The panel will discuss FERC penalties, recent enforcement actions, FERC and CFTC anti-manipulation rules, self-reporting programs, and compliance practices that can help avoid and mitigate penalties and liability.


Energy companies are subject to significant scrutiny of trade practices and related transactions. Recent developments in enforcement actions by FERC and CFTC have highlighted large penalties, self-reporting obligations, anti-manipulation rules and key items of focus during audits.

FERC and CFTC have emphasized their intent to penalize violations such as market manipulation and fraud. In the absence of sufficient evidence of market manipulation and fraud, other matters, such as tariff violations, unintentional errors and reporting mistakes, will be the focus of enforcement and assessment of penalties for energy companies.

On Jan. 8, 2019, FERC issued final rules amending regulations to increase the maximum civil monetary penalties for violations of statutes, rules and orders within its jurisdiction. Also, the CFTC has increased efforts on accountability and self-reporting, potentially leading to individual liability. The CFTC filed 83 enforcement actions in 2018, obtaining $947 million in penalties and restitution. Both FERC and the CFTC have solidified strict anti-manipulation rules in connection with transactions involving electric energy, natural gas, or the purchase or sale of transmission or transportation services subject to their jurisdiction.

Listen as our panel discusses FERC penalties, recent violations and enforcement actions, navigating the anti-manipulation rules, and best practices for managing surveillance calls, self-reporting, and achieving compliance with FERC and CFTC rules relevant to energy trading.



  1. Recent FERC enforcement actions and impact on energy trading
  2. FERC penalties and how to avoid or mitigate them
  3. Recent CFTC enforcement actions and effects of anti-manipulation rules
  4. Essential items of interest in FERC and CFTC surveillance calls
  5. Available self-reporting options and avoiding penalties and litigation


The panel will review these and other key issues:

  • Recent FERC and CFTC enforcement actions and penalties and how to avoid or mitigate them
  • The impact of FERC and CFTC anti-manipulation rules on energy trading and transactions
  • CFTC cooperation policy and self-reporting options
  • Avoiding errors and reporting mistakes, and other good compliance practices
  • Potential individual liability


Applebaum, David
David A. Applebaum

Akin Gump Strauss Hauer & Feld

Mr. Applebaum counsels energy and other industry clients, representing them in energy regulatory enforcement matters...  |  Read More

Asaro, Michael
Michael A. Asaro

Akin Gump Strauss Hauer & Feld

Mr. Asaro focuses on white collar criminal defense, SEC and Commodity Futures Trading Commission (CFTC) investigations,...  |  Read More

Brecher, Todd
Todd L. Brecher

Akin Gump Strauss Hauer & Feld

Mr. Brecher focuses on energy litigation, regulatory and enforcement matters before federal and state agencies and...  |  Read More

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