Posted: 01 Oct. 2020 2 min. read

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.

Key contacts

Katie Jackson

Katie Jackson


Katie is a Partner in Deloitte Forensic. She has over 10 years’ experience working in the Financial Services sector, principally specialising in Financial Crime. She has a particular focus on anti-money laundering (AML) and financial sanctions, supporting clients to comply with regulatory obligations and keep abreast of industry good practice. More recently, she has been supporting projects looking to redesign financial crime target operating models.

Stacey Toder Feldman

Stacey Toder Feldman


An international trade lawyer by background, Stacey Toder Feldman is a Director in the Firm's Forensic practice and leads the Energy and Resources team. Stacey has over 20 years’ experience advising clients on all aspects of the economic crime compliance lifecycle, in particular on global export controls, sanctions, customs, anti-bribery and corruption and fraud. Stacey’s practice covers a wide range of industries, with a particular focus on Energy, Resources and Industrials, specifically on oil and gas, chemicals, manufacturing, trading, shipping, metals and mining and wider energy matters. She specialises in conducting complex, multi-jurisdictional investigations and identifying areas of risk and opportunity, with emphasis on developing tailored compliance frameworks designed to minimise economic crime risk for businesses.

Rawad Halawi

Rawad Halawi

Director, Financial Advisory

Rawad is a Director with the Deloitte Forensic Team. He specialises in delivering change/transformation programmes and solutions in the financial services industry. Specialist in Financial Crime (FC), Anti-Money Laundering (AML), Counter-Terrorist Financing (CTF) and Sanctions. Experience across Governance, Policy, Process, Operating Model Design/Delivery, Change Management, Digital Transformation and Automation.