About
Heightened scrutiny, stepped-up enforcement and
changing standards....Is your energy trading compliance program keeping pace with the changing market realities?
Compliance, investigations and enforcement are heating up rapidly for companies that trade energy. With FERC now conducting in-depth compliance inquiries, the pressure has intensified as FERC has ordered investigated companies to spend specified amounts of money on compliance programs – usually in the $1M to $2M range. Cooperation between FERC and the CFTC is on the rise as they increasingly investigate commodities trading. Congress recently enhanced the CFTC’s civil penalty authority on market manipulation, and provided it with authority to focus on “significant price discovery contracts” on exchanges like ICE in an attempt to close the so-called “Enron loophole”. And now the new player – the FTC – is seeking anti-manipulation authority, particularly relevant for those in the oilpatch who have only had minimal oversight by FERC to date.
With increased oversight and enforcement actions, larger penalties, recent
litigation over alleged non-compliance, and multiple regulators, ensuring you
are covering all the bases in your company’s compliance programs has taken on an unprecedented importance.
ACI’s Energy Trading Compliance Conference provides a one-of-a-kind forum
for energy firms, traders and their advisors to convene and get the practical answers you need for managing compliance challenges in a time of uncertainty and rapid change. Attend and gain critical information on:
- FERC’s implementation of real-time monitoring in connection with futures activity:
how does FERC’s increasing presence in the futures arena affect CFTC oversight?
- Market manipulation, OATT violations, capacity release shipper-must-have-title, FPA section 203, MBRs: where regulator activity is focused most now?
- Drawing the line between legitimate risk-taking and price setting vs. market manipulation
- Assessing your organizational structure and communications between merchant
and transmission employees for risk of violating standards of conduct
- Self-reporting when you find a violation: how do you assess the risks and benefits?
Don’t miss this opportunity to learn about new and developing compliance initiatives and benchmark your compliance efforts and programs against those
of your peers. Spaces will go quickly so register now.
About
Heightened scrutiny, stepped-up enforcement and
changing standards....Is your energy trading compliance program keeping pace with the changing market realities?
Compliance, investigations and enforcement are heating up rapidly for companies that trade energy. With FERC now conducting in-depth compliance inquiries, the pressure has intensified as FERC has ordered investigated companies to spend specified amounts of money on compliance programs – usually in the $1M to $2M range. Cooperation between FERC and the CFTC is on the rise as they increasingly investigate commodities trading. Congress recently enhanced the CFTC’s civil penalty authority on market manipulation, and provided it with authority to focus on “significant price discovery contracts” on exchanges like ICE in an attempt to close the so-called “Enron loophole”. And now the new player – the FTC – is seeking anti-manipulation authority, particularly relevant for those in the oilpatch who have only had minimal oversight by FERC to date.
With increased oversight and enforcement actions, larger penalties, recent
litigation over alleged non-compliance, and multiple regulators, ensuring you
are covering all the bases in your company’s compliance programs has taken on an unprecedented importance.
ACI’s Energy Trading Compliance Conference provides a one-of-a-kind forum
for energy firms, traders and their advisors to convene and get the practical answers you need for managing compliance challenges in a time of uncertainty and rapid change. Attend and gain critical information on:
- FERC’s implementation of real-time monitoring in connection with futures activity:
how does FERC’s increasing presence in the futures arena affect CFTC oversight?
- Market manipulation, OATT violations, capacity release shipper-must-have-title, FPA section 203, MBRs: where regulator activity is focused most now?
- Drawing the line between legitimate risk-taking and price setting vs. market manipulation
- Assessing your organizational structure and communications between merchant
and transmission employees for risk of violating standards of conduct
- Self-reporting when you find a violation: how do you assess the risks and benefits?
Don’t miss this opportunity to learn about new and developing compliance initiatives and benchmark your compliance efforts and programs against those
of your peers. Spaces will go quickly so register now.
Contents & Contributors
FERC, CFTC and FTC Priorities, Overlap and Coordination: What the Evolving Regulatory Framework Means for Your Compliance Program
Peter Richman, Deputy Assistant Director, Bureau of Competition, FTC (Washington, DC)
Geoffrey Aronow, Partner, Bingham McCutchen LLP, Former Director of Enforcement, CFTC (Washington, DC)
Sheila Slocum Hollis, Partner, Duane Morris LLP, Former First Director of the Office of Enforcement of FERC (Washington, DC)
Lessons Learned from Recent FERC & CFTC Litigation and Settlements
John Moot, Partner, Skadden, Arps, Slate, Meagher & Flom LLP, Former Chief of Staff and General Counsel, FERC (Washington, DC)
Robert Fleishman, Partner, Covington & Burling (Washington, DC)
Drawing the Line Between Legitimate Price-Setting/Risk-Taking and Market Manipulation in a Shifting Regulatory Environment
Charles Cerria, Assistant General Counsel-Trading, Hess Corporation (New York, NY)
Avoiding Allegations of Affiliate Abuse and Other Pitfalls
Michael Sweeney, Partner, Hunton & Williams (Washington, DC)
Antoine P. Cobb, Manager, Federal Regulation, Arizona Public Service Company (Phoenix, AZ)
FERC and CFTC Audits and Investigations: Responses and Approaches For Mitigating Penalties and Reputational Harm
Larry Eisenstat, Energy Practice Leader, Partner, Dickstein Shapiro LLP, (Washington, DC)
Joel B. Kleinman, Partner, Dickstein Shapiro LLP (Washington, DC)
What to do When you Find a Violation: Benefits and Cautions When Self Reporting
Jeffrey Perryman, Director, Compliance, Atmos Energy Corporation (Dallas, TX)
Regina Y. Speed-Bost, Partner, Schiff Hardin LLP, Former Advisory and Trial Attorney at FERC (Washington, DC)
Best Practices for Creating a Compliance Program that Meets FERC Requirements
Stephen R. Melton, Vice President & Deputy General Counsel, NiSource Corporate Services Company, Chief FERC Compliance Officer for the NiSource Pipelines and North Indiana Public Service Company (Houston, TX)
Andrew S. Katz, Senior Counsel, Northeast Utilities (Washington, DC)
John L. Doran, Principal, SunGard (Houston, TX)
Peggy A. Heeg, Partner, Fulbright & Jaworski L.L.P. (Houston, TX)
Conducting a Risk Assessment of your Energy Trading Compliance Program
Bray M. Dohrwardt, Director, Government and Regulatory Affairs, Direct Energy, (Houston, TX)
Hon. Sharon Brown-Hruska, Ph.D., NERA Economic Consulting, Former Commissioner and Acting Chairman, CFTC (Washington, DC)
Alan Bransgrove, Director of Risk Control, Xcel Energy (Denver, CO)
Publication Details