What Can Energy Companies Expect From the CFTC in 2019?

What Can Energy Companies Expect From the CFTC in 2019?

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This is the fourth issue of WilmerHale’s 10-in-10 Hot Topics in Energy Series. Over the course of 10 weeks, our attorneys will share insights on current and emerging issues affecting the US energy sector. Attorneys from across various practice groups at the firm will offer their take on issues ranging from congressional investigations, to the impact of key regulatory reforms, to emerging trends in domestic litigation and international arbitration. Read our other recent publications.

The CFTC engaged in robust enforcement in 2018, and shows no indication of slowing down. The agency has also consistently highlighted the importance it places on its new "cooperation" policy as part of its enforcement regime. In this article, I discuss, among other things, some of the considerations energy companies may have in deciding whether to pursue "cooperation" strategy with the CFTC.

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This client alert was republished by Law360.

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