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Michael W. Brooks
P: +1.202.828.5879
F: +1.800.404.3970

Michelle Disse


Michael focuses his practice in the areas of energy, commodities and derivatives law. He represents energy companies and commodity trading companies in a wide variety of regulatory, compliance and enforcement matters and routinely advises clients regarding compliance with federal rules and regulations governing the trading, ownership and transportation of energy commodities.

In addition to actively representing clients in investigations and regulatory matters involving the Federal Energy Regulatory Commission (FERC), the Commodity Futures Trading Commission (CFTC) and designated contract markets such as CME Group and ICE Futures U.S., Michael conducts internal compliance reviews and trainings, works with clients to develop effective compliance programs and collaborates with commercial teams to structure large commodity transactions and acquisitions to comply with FERC and CFTC regulations. He also advises clients regarding compliance with the Dodd-Frank Wall Street Reform and Consumer Protection Act of 2010.  Michael also advises clients regarding the U.S. Federal Trade Commission’s (FTC) petroleum market manipulation regulations.

Representative Matters

Representing multiple clients in non-public, FERC investigations surrounding allegations of manipulation of natural gas and electricity markets, including responding to data requests, defending depositions, responding to preliminary conclusions and settlement negotiations.

Representing clients in non-public investigations conducted by the CFTC involving energy and agricultural commodities and metals, including responding to document requests, taking of testimony, and responding to Wells Notices.

Representing large, multinational companies in extraterritorial investigations conducted by the CFTC, including addressing jurisdictional questions and protocols under international memoranda of understanding.

Representing and/or advising clients in non-public exchange inquiries from CME Group and ICE Futures U.S. related to allegations of fraud, fictitious trades, wash and accommodation trades, non-bona fide exchanges for related position (EFRPs) and block trades.

Conducting investigations and reviews of compliance practices and advising clients regarding implementation of effective compliance programs.

Conducting compliance trainings for clients engaged in commodities trading.

Providing transactional advice regarding regulatory compliance.

Advising a major LNG importer regarding a broad range of issues arising from the importation, transportation and storage of LNG.

Advising clients on pipeline-specific matters and on general rulemaking proceedings at FERC.

Advising clients regarding bilateral negotiations related to natural gas trading and transportation.

Publications and Speeches

“Court Clarifies Application of FERC Anti-Manipulation Rule to Demand Response Service Providers,” Electric Light & Power, July 2016.

“Handling Change Management,” Midstream Business, February 2016.

Co-author, "CFTC v. Kraft Foods: What is Market Manipulation?" The National Law Review, July 16, 2015.

"Operating a Utility in Today’s Enforcement Climate: FERC and Beyond," Utilities & Energy Compliance & Ethics Conference, February 2015.

"Takeaways from FERC’s Recent Due Diligence Order," Law360, February 2013.

Speaker, "CFTC Trading Rule Changes and FERC Update," April 14, 2011.

Speaker, "The US Regulatory Landscape: Financial Reform and the Dodd-Frank Bill: What is the emerging picture on hedging, swaps markets, clearing? How will this impact refiners’ and producers’ ability to efficiently hedge operations?" January 27, 2011.

Speaker, "Creating a Culture of Compliance within Your Company," September 1, 2010.

Speaker, "Central Clearing - Questions and Answers from the Buy-Side Perspective," April 25, 2010.

Co-author, "Reviewing LNG Regulations," Pipeline and Gas Technology, November 2007.

Co-author, "Liquefied Natural Gas (LNG) Litigation After the Energy Policy Act of 2005," Energy Law Journal, November 14, 2006.

Co-author, "U.S. Gas Interchangeability Policy Ripples Through Global LNG Industry," LNG Observer, October/December 2006.

Co-author, "Liquefied Natural Gas (LNG) Litigation After the Energy Policy Act of 2005: State Powers in LNG Terminal Siting," Energy Law Journal, 2006.


J.D., magna cum laude, George Mason University School of Law, 2005
B.A., College of William & Mary, 1998

Bar Admissions

District of Columbia


American Bar Association
Energy Bar Association


Legalease, The Legal 500 United States, Energy: Regulatory, 2012, 2016
Senior Notes Editor, George Mason Law Review
2007 Burton Award for Legal Achievement for “Liquefied Natural Gas (LNG) Litigation After the Energy Policy Act of 2005,” Energy Law Journal (November 14, 2006)
Thomson Reuters, Washington, D.C. Rising Star, 2013-2016