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Financial Crime in the Energy Trading & Supply sector: The New Compliance Frontier

Building a comprehensive and robust Financial Crime risk management program that is both effective and cost efficient is a longstanding challenge for many organisations and one that has become increasingly pertinent with the growing financial pressures posed by COVID-19.

Previously, many energy trading & supply organisations have focussed their compliance efforts on their biggest risk exposures, such as the market abuse risks associated with the trading of financial instruments. However, the recent increased regulatory scrutiny on this sector, including published US and UK regulatory guidance, various enforcement cases and regulatory enquiries highlight that such organisations are now expected to address the wider spectrum of financial crime risks. As a result, organisations are now having to rapidly adapt and expand beyond the comfort-zone of the regulation of financial instruments and explore the financial crime risks associated with their physical market activities and associated trading operations, which in the past were primarily regulated from a consumer protection and competition perspective. This narrowed focus means that many organisations are now struggling to implement holistic financial crime compliance arrangements in a cost effective manner across all of their physical and financial operations. This in turn increases the risk of failing to meet their compliance obligations and lead to potential reputational and regulatory issues.

While there are lessons to be learned for energy trading & supply organisations from the financial services sector, there is ultimately no ‘one size fits all’ solution for financial crime risk management and the differences between energy trading & supply organisations and those in the financial services sector need to be accounted for and tailored solutions developed. Here at Deloitte, we are working with our clients in this space to re-define financial crime risk management and explore how taking an integrated approach can help to deliver in line with the business strategy by making compliance a competitive differentiator. We are helping our clients enhance their capabilities, control costs and deliver sustainable compliance. Through our targeted blog series on this topic (“Perspectives”), we will explore some of the unique aspects of financial crime risk that arise in energy trading & supply organisations and explore potential answers to the following key questions:

1. How do we effectively incorporate our financial crime risk management program in to the broader compliance program?

2. How does understanding my risk exposure help drive our strategy and understand our risk appetite?

3. What lessons can we learn from the financial services sector around an effective control environment and how can we leverage existing operational controls used within the compliance program and repurpose them to manage financial crime risks?

4. How do we transform our business so that we meet regulatory expectations and our risk appetite in a time and cost effective manner?

Having identified the need for our clients to understand their exposure to all financial crime risks across both their physical and financial operations, we have helped our energy trading and supply clients to design, build and execute a more comprehensive and integrated approach to financial crime risk management that is tailored to the unique aspects of their business. Please join us in the next instalment of our Perspectives when we explore ways in which you can incorporate your financial crime risk management program in to your broader compliance program in more detail.

For further information in relation to this topic, please contact Katie Jackson, Rawad Halawi or Stacey Toder Feldman.

Meet the authors

Katie Jackson


Katie is the Partner in charge of Deloitte’s UK Forensic practice. With over 23 years’ experience working in the Financial Services industry and more recently in the energy and commodities trading sector, Katie has significant experience in Financial Crime, regulatory investigations, and transformation programmes. Katie sits on the firm’s FS Women in Leadership Council and is passionate about supporting diversity and inclusion at work and was a previous winner of the UK Timewise Power Part-Time list in 2014.  

Stacey Toder Feldman

UK Mining & Metals Leader | EMEA Forensic ER&I Lead

An international lawyer by background, Stacey Toder Feldman leads our Forensic practice for the Energy, Resources and Industrials industry across EMEA and is also the UK Mining & Metals Sector Lead. Stacey has over 20 years’ experience advising clients on all aspects of the economic crime compliance lifecycle, in particular on global export controls, trade and economic sanctions, customs fraud, anti-bribery and corruption, fraud and related workplace misconduct. She provides a range of advisory and reactive services including: complex, multi-jurisdictional investigations; regulatory driven enquiries and related settlement agreements; risk assessments; target operating model design; gap analyses; forensic SME audit support; M&A due diligence; internal investigations and workplace misconduct matters; voluntary self-disclosures and related corrective actions. Stacey also specialises in designing bespoke global outsourced and co-sourced managed investigations services. Stacey works with clients from a wide range of industries, with a particular focus on energy, resources and industrials, and especially mining and metals, oil and gas, chemicals, manufacturing, trading, shipping, and industrial products. Stacey co-leads our firm’s critical minerals strategy campaign and recently authored an article series looking at the supply chain challenges of critical minerals. A strong supporter of the diversity agenda and promoting inclusion in the workplace, Stacey is co-partner sponsor for Deloitte’s Gender Balance Network and supports a range of people and purpose-related initiatives across the firm.

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