Sep 222015

Energy Enforcement Update

Kenneth W. Irvin, Terence T. Healey, Christopher J. Polito and Sharon Rose
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Yesterday, FERC issued a Notice of Alleged Violation naming Total and two traders.

Staff alleges that the scheme involved making largely uneconomic trades for physical natural gas during bid week designed to move indexed market prices in a way that benefited the company’s related positions. Staff also alleges that the West Desk implemented the bid week scheme on at least 38 occasions during the period of interest.  Staff further alleges that Therese Nguyen and Aaron Hall each implemented the scheme and supervised and directed other traders in implementing the scheme.

FERC Notice of Alleged Violations

Kenneth W. Irvin

Washington, D.C.

kirvin@sidley.com

Terence T. Healey

Boston

thealey@sidley.com

Christopher J. Polito

Washington, D.C.

cpolito@sidley.com

Sharon Rose

srose@sidley.com

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