FERC’S Enforcement Order on GreenHat and Takeaways for Market Participants

March 7, 2022

The Federal Energy Regulatory Commission recently issued a significant enforcement order finding that GreenHat Energy, LLC engaged in a fraudulent scheme in the Financial Transmission Rights market operated by PJM. GreenHat’s default resulted in nearly $180 million in losses, almost all of which were shouldered by market participants. The attached client alert outlines the scope of GreenHat’s scheme and the subsequent fallout, and reviews significant takeaways for FERC-regulated market participants. If you have questions about FERC enforcement in organized markets or need advice on best practices for market participation, please contact us.

You can view the client alert at the link below.