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
Active monitoring in place across Energy, Power & Commodities. Material developments related to anti-money laundering compliance programs will appear here as they are published.