BARRELThree patterns account for 84% of all energy trading enforcement actions.
Case Studies
Details redacted per attorney-client privilege. All cases are public FERC, CFTC, or ACER docket records.
Virtual Bidding Desk Triggers Wash-Sale Flag
A Houston-based independent trading shop running basis swaps across the SPP-MISO seam accumulated a pattern of offsetting virtual bids that FERC's surveillance identified as non-economic — the desk had no documented rationale for the positions.
████████████████ filed a motion to dismiss arguing ████████████████
Settlement reached at ████████ with a compliance program requirement extending through ████
Large Trader Reporting Gap — Natural Gas Futures
An integrated major's in-house derivatives team failed to file accurate Form 102A submissions for 14 consecutive reporting periods. The gap was discovered during a routine CFTC audit, not by internal compliance.
Chief Compliance Officer ████████████ acknowledged in testimony that ████████████████████
Remediation required ████████████ and ████████████████ at a cost exceeding ████████
Gas Storage Operator Exceeds Reportable Threshold
A midstream operator running basis swaps against storage obligations crossed the REMIT reportable position threshold on 23 non-consecutive days without filing the required inside information notifications to the relevant NRA.
Internal legal counsel concluded that ████████████████████ did not constitute inside information under ████████
ACER disagreed. The NRA issued a ████████████████ with ████████████ monitoring conditions.
A framework built from every enforcement action filed since 2019.
The Barrel Exposure Assessment is not a checklist. It is a probabilistic model trained on public enforcement data, weighted by penalty size, recurrence rate, and jurisdictional enforcement appetite. The seven-question intake maps your firm to the quadrant where your risk concentrates.
Surveillance Ingestion
Continuous parsing of FERC CEII feeds, CFTC Large Trader reports, and REMIT NRA bulletins — updated within 4 hours of publication.
Pattern Classification
Seven violation archetypes mapped against your firm's commodity focus, jurisdiction footprint, and trading strategy profile.
Exposure Scoring
Probabilistic scoring across 34 risk factors derived from 340+ enforcement actions. Not rules-based — evidence-weighted.
Gap Analysis Report
A one-page privileged summary maps your highest-probability exposure vectors to specific regulatory obligations and remediation steps.
Seven questions. Your Compliance Exposure Score.
Firmographic questions first, then behavioral. Your answers are not stored. The risk meter updates in real time. Completion unlocks your personalized PDF summary — the detailed gap analysis requires a direct consultation request.
What is your firm's primary commodity focus?
Answers are processed client-side only. No data is transmitted until you explicitly submit a consultation request.