Following the declaration of a global pandemic due to the widespread transmission of the coronavirus (COVID-19), the issuance of shutdown and/or stay-at-home directives cascaded from commercial enterprises and state and local governments across the United States. During this period of extreme disruption to daily routine, the continuity and integrity of energy operations were necessary to ensure that the massive shift to home-based life could exist with minimal business disruption. Front- and back-office personnel engaged in trading energy commodities quickly transitioned to a work-from-home (WFH) posture, ensuring that their firms could preserve market access for production or output while also consummating the transactions needed to procure an adequate fuel source, managing price exposure to highly volatile commodity prices, or executing preexisting trading strategies.
Although the various shutdown and stay-at-home orders are expiring or easing in applicability, we expect many personnel to remain in a WFH environment for the foreseeable future. As we anticipate a world in which businesses operate in fundamentally new and different ways and individuals engage in a prolonged WFH environment for one or more days per week, it is essential that energy compliance, legal, and risk management personnel draw on lessons learned since the onset of COVID-19 and adapt existing compliance programs or oversight to the new normal.
Morgan Lewis has prepared a White Paper identifying and discussing some of the most important issues that compliance and legal personnel should consider to make sure that existing compliance programs remain effective and adequately address the unique challenges presented by energy commodity trading in a remote environment.