Suspicious activity reporting

Suspicious activity reporting in the Energy, Power & Commodities sector sits at the intersection of anti-money laundering obligations and commodity market integrity rules enforced by the Financial Crimes Enforcement Network, the U.S. Commodity Futures Trading Commission, and the Federal Energy Regulatory Commission. FinCEN's SAR filing requirements apply to futures commission merchants and introducing brokers active in energy derivatives, while FERC's anti-manipulation authority under the Energy Policy Act of 2005 creates parallel disclosure pressure when trading patterns suggest wash trades or fictitious transactions. Compliance teams are the ones holding both frameworks at once, and the threshold questions around when an energy trade triggers a SAR obligation versus a FERC referral remain genuinely unsettled.