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About Michael

Michael Brooks 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, transportation and transmission 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 and the U.S. Federal Trade Commission’s (FTC) petroleum market manipulation regulations.                              

Clients say Michael Brooks is 'very helpful in providing clear direction and advice related to very complex topics.'
Chambers USA, 2017


Recent Notable Matters

Energy companies — representing clients in non-public investigations conducted by FERC surrounding allegations of manipulation of natural gas and electricity markets

Large Commodity Trading Companies — representing clients in non-public investigations conducted by the CFTC involving energy and agricultural commodities and metals

Non-U.S. companies — representing clients in extraterritorial investigations conducted by the CFTC, including raising jurisdictional defenses and operating pursuant to protocols in keeping with international memoranda of understanding

Participants in U.S. futures markets — 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, spoofing, non-bona fide exchanges for related position (EFRPs), block trades, and position limit violations

ISO/RTO market participants — advising clients regarding transaction-specific compliance and/or representing clients in non-public investigations related to trading in the various ISOs/RTOs, including PJM Interconnection, ISO New England, the New York ISO, the Midcontinent Independent System Operator (MISO), the Southwest Power Pool (SPP), the California ISO (CAISO) and the Electric Reliability Council of Texas (ERCOT)

Small businesses to large and multinational companies — conducting investigations and reviews of compliance practices and advising clients regarding implementation of effective compliance programs, conducting compliance trainings, and providing transactional advice regarding regulatory compliance

LNG importers/exporters — advising regarding a broad range of issues arising from the importation, exportation, transportation and storage of LNG

Publications and Speeches

“Another Year of Enforcement at FERC and CFTC,” Law360, January 2017.

“Court Clarifies Application of FERC Anti-Manipulation Rule to Demand Response Service Providers,” Electric Light & Power, July 19, 2016.

“Handling Change Management,“ Midstream Business, February 12, 2016.

“Operating a Utility in Today’s Enforcement Climate: FERC and Beyond,“ Utilities & Energy Compliance & Ethics Conference, February 24, 2015.



George Mason University School of Law,
magna cum laude
College of William & Mary,

Bar Admissions

District of Columbia


American Bar Association
Energy Bar Association



Handling Change Management

February 12, 2016
Midstream Business

Did Kraft manipulate futures?

October 21, 2015

CQ Today

May 13, 2011
Roll Call

Knowledge Center



Chambers USA
Nationwide, Energy: Oil & Gas (Regulatory & Litigation), 2017
The Legal 500 United States
Energy Regulatory: Conventional Power, 2017; Energy Regulatory: Oil and Gas, 2017; Energy: Regulatory, 2016


Past Events