Insider trading surveillance
Insider trading surveillance in Energy, Power & Commodities sits at the intersection of securities law and physical market conduct, drawing scrutiny from the U.S. Securities and Exchange Commission, the U.S. Commodity Futures Trading Commission, and the Federal Energy Regulatory Commission simultaneously. The CFTC's Regulation 23.203 recordkeeping requirements and FERC's Anti-Manipulation Rule under the Energy Policy Act of 2005 create overlapping obligations that compliance teams cannot treat as separate workstreams. Firms trading power, natural gas, or commodity derivatives are now expected to run surveillance programs that connect physical position data to financial instrument activity across the same desks.
Watch
- FERC Anti-Manipulation Rule enforcement actions involving basis trades and physical scheduling
- CFTC swap dealer surveillance obligations under Part 23 for energy derivatives desks
- Cross-market manipulation patterns linking physical dispatch to futures positions
- SEC Staff Bulletin on Material Nonpublic Information from alternative data sources in commodities
- FERC Order 1000 interconnection data: watch for misuse as a precursor to trading activity
Recent material activity in Energy, Power & Commodities
Active monitoring in place across Energy, Power & Commodities. Material developments related to insider trading surveillance will appear here as they are published.