Anti-Money Laundering compliance programs
Anti-money laundering compliance in the Energy, Power & Commodities sector sits at the intersection of physical commodity flows, financial settlement, and cross-border counterparty risk, drawing direct scrutiny from the U.S. Financial Crimes Enforcement Network, the U.S. Commodity Futures Trading Commission, and the European Banking Authority. FinCEN's 2024 proposed rule on investment advisers signaled an expanding perimeter for AML program obligations that commodity trading advisers and energy trading firms are already benchmarking against. Compliance teams in this sector are auditing correspondent banking relationships and trade finance documentation now, not waiting for final rulemaking.
Watch
- FinCEN's proposed AML program rule for investment advisers: applicability to commodity trading advisers
- CFTC guidance on swap dealer AML obligations and suspicious activity reporting thresholds
- EU Transfer of Funds Regulation expanded crypto-asset coverage affecting tokenized commodity settlement
- Sanctions-linked beneficial ownership gaps in physical energy trading counterparty due diligence
- FATF Recommendation 22 revisions and their pull-through into U.S. non-financial business AML expectations
Recent material activity in Energy, Power & Commodities
A selection of recent published briefs; this is not a complete archive.
CFTC obtains federal court orders against EminiFX and Eddy Alexandre for commodity pool Ponzi scheme
The CFTC announced on October 19, 2026 that the U.S. District Court for the Southern District of New York entered orders granting the CFTC's motions for summary judgment, injunctive relief, and a civil monetary penalty a…
Read a full sample brief →DOE commits up to $42 million in Defense Production Act funds to advance Constitution Pipeline development
The U.S. Department of Energy announced on October 19, 2026 that it will deploy up to $42 million in Defense Production Act Title III funding to advance a proposed 125-mile natural gas pipeline from Pennsylvania to New Y…
Read a full sample brief →DOE announces intent to deploy Defense Production Act funding for Virginia and West Virginia transmission expansion
The U.S. Department of Energy announced on October 16, 2026 its intent to deploy Defense Production Act funding to accelerate transmission capacity expansion in Virginia and West Virginia. The project is framed as streng…
Read a full sample brief →EPA co-proposes two approaches to revise 2026 and 2027 RFS small refinery exemption reallocation volumes
EPA published a proposed rulemaking on October 16, 2026 to revise the 2026 and 2027 Renewable Fuel Standard small refinery exemption reallocation volumes. The proposal responds to a higher volume of 2025 small refinery e…
Read a full sample brief →DOE publishes Emissions Value Request Process supporting Treasury and IRS administration of the Clean Fuel Production Credit
The U.S. Department of Energy (DOE) published a Notice of Availability on October 16, 2026, establishing an Emissions Value Request Process to support Treasury and IRS administration of the section 45Z Clean Fuel Product…
Read a full sample brief →FERC opens additional scoping period for Gulf South Pipeline Texas Gateway Project EIS
FERC staff have opened a second public scoping period for the Texas Gateway Project, a natural gas pipeline proposed by Gulf South Pipeline Company, LLC across seven Texas counties and Beauregard Parish, Louisiana. The C…
Read a full sample brief →Estonian Competition Authority fines Futugrid €16,000 in its first REMIT market-manipulation decision, subject to appeal
The Estonian Competition Authority (Konkurentsiamet) has fined Futugrid Technologies OÜ €16,000 for placing a non-genuine bid in the Baltic balancing energy market on 1 April 2025. The bid sent misleading signals and dir…
Read a full sample brief →AER invites submissions on Transgrid's $9.34 million network support cost pass through application for 2025-26
The Australian Energy Regulator (AER) has opened a public consultation on Transgrid's cost pass-through application for network support costs incurred in 2025-26. Transgrid has identified a net positive pass-through amou…
Read a full sample brief →AER invites submissions on ElectraNet's $18.6 million storm cost pass-through application for South Australian transmission network
The Australian Energy Regulator (AER) has opened a public consultation on ElectraNet's cost pass-through application for transmission network damage caused by the 17 October 2024 storm. ElectraNet has identified $18.6 mi…
Read a full sample brief →AER publishes draft decision to grant AGN ring-fencing exemptions for two hydrogen trial projects
The Australian Energy Regulator (AER) published a draft decision on October 16, 2026 proposing to grant Australian Gas Networks Limited (AGN) exemptions from gas ring-fencing obligations for its Hydrogen Park South Austr…
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