Casey Khan

CASEY KHAN represents clients on a variety of regulatory, enforcement, compliance, and transactional matters involving the U.S. electricity, natural gas, and commodity markets. Casey has over 15 years of experience working directly on commodity and financial trading floors in risk management, legal, and compliance functions. His advisory experience includes trading and hedging operations, risk management controls, and the creation and implementation of robust compliance programs.

Casey recognizes the complexity of operating in a fast-paced competitive market environment, and the need for high-integrity transaction analysis when advising clients and practicing before U.S. exchanges and regulatory commissions.

Additionally, Casey represents institutions in regulatory proceedings, inquiries, and investigations before the Commodity Futures Trading Commission (CFTC), Federal Energy Regulatory Commission (FERC), and various Commodity & Derivative Exchanges (CME, ICE). He regularly advises and coaches commodity traders, marketers, and operators on physical and financial transactions, exchange rules, regional energy market rules and tariff requirements, and issues related to the design and operation of commodity derivatives, wholesale energy, and capacity markets. Casey also advises commodity, energy, and financial institutions on regulatory requirements under the Commodity Exchange Act, the Dodd-Frank Act, the Federal Power Act, the Natural Gas Act, the Foreign Corrupt Practices Act, and relevant commodity provisions of the Bank Holding Company Act.

Casey’s experience includes successfully defending institutions on enforcement and anti-manipulation cases under CFTC and FERC regulation for investigations initiated by regulatory staff, whistleblowers, or self-reported. 

Prior to joining Sidley, he worked for the legal and compliance divisions of commodity, energy, and financial trading organizations. He is a veteran who served honorably in the U.S. Marine Corps Reserve.  

Casey’s experience prior to joining Sidley includes:

• Guiding and developing teams of legal and compliance professionals to provide compliant regulatory advice to trading and commercial operations of oil liquids, power, natural gas, and emissions markets as they pertain to the Commodity Exchange Act (CEA), Dodd-Frank Act, Federal Power Act, Natural Gas Act, Bank Holding Company Act, and other related standards.
• Advising traders directly on swaps, futures, and physical transactional issues, including: exchange rules (CME, NYMEX, ICE, Nodal) regarding futures position limits, hedge exemptions, block trades, exchange for related positions (EFRP), and energy deliveries.
• Leading, performing, and developing surveillance and investigations of energy trading transactions and operations to ensure high integrity and compliance with regulatory statutes, particularly to mitigate complex market abuse, market manipulation, and disruptive trade practice risks.
• Representing a client in connection with the acquisition of a wind generation facility.
• Representing a commodity trading company in enforcement matters before the CME, NYMEX, and CBOT Business Conduct Committees.
• Representing financial institutions and energy trading companies in inquiries conducted by ICE, CME, NYMEX, CBOT, and Nodal exchanges.
• Providing regulatory advice related to ISO/RTO tariffs (including PJM, CAISO, ERCOT, MISO, PJM, NYISO, SPP) and natural gas pipeline and storage facility tariffs and agreements.
• Advising financial institutions and energy trading companies in internal and external investigations, as well as self-reports to CFTC and FERC.
• Advocating on behalf of an energy trading company for regulatory positions related to CFTC, FERC, and Exchange proposals, sometimes building consensus with regulators and in forums like the Futures Industry Association.
• Conducting compliance training and drafting compliance handbooks for financial institutions and energy trading companies on CFTC, FERC, and Banking regulations.

• Future Industry Association, Law and Compliance Executive Committee Member – May 2020 to May 2021