Subject to Inquiry

Subject to Inquiry

THE LATEST ON GOVERNMENT INQUIRIES AND ENFORCEMENT ACTIONS

Government Investigations and White Collar Litigation Group

Todd Mullins

Photo of Todd Mullins Todd serves as chair of the Energy Enforcement practice group. He represents energy clients with enforcement and compliance matters involving the Federal Energy Regulatory Commission (FERC), the Commodity Futures Trading Commission (CFTC), the North American Electric Reliability Corporation (NERC) and other regulators, as well as related government and private litigation.

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CFTC: Calling All Whistleblowers in Carbon Markets

By Todd Mullins on Energy Enforcement, Enforcement and Prosecution Policy and Trends, Fraud, Deception and False Claims
With an “alert” issued June 20, the Commodity Futures Trading Commission is targeting carbon markets by asking whistleblowers to come forward with information about fraudulent or manipulative trading of carbon credits and other environmental commodities as well as related derivatives. Read on for details about the CFTC’s alert and implications for entities that trade in… Continue Reading

FERC’s New Infrastructure and Environmental Impacts Priority – What to Expect in Enforcement Cases

By Todd Mullins and Carrie Mobley on Energy Enforcement
The Federal Energy Regulatory Commission (FERC) Office of Enforcement (OE) has historically focused on four “priorities,” as described in its annual Report on Enforcement. Those four priorities included (1) fraud and market manipulation; (2) serious violations of Reliability Standards; (3) anticompetitive conduct; and (4) conduct that threatens the transparency of regulated markets. In the 2021… Continue Reading

FERC Directs NERC to Amend its Sanctions Guidelines by July 21, 2020

By Todd Mullins and Katlyn A. Davis Farrell on Compliance, Energy Enforcement
Entities registered with the North American Electric Reliability Corporation (NERC) to comply with mandatory electric reliability standards (Reliability Standards) or face civil penalties should take note of an order issued by the Federal Energy Regulatory Commission (FERC) on January 23, 2020 in Docket No. RR19-7-000 (January 23 Order).  In the January 23 Order, FERC, which oversees NERC… Continue Reading

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