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Jeremy Medovoy

Jeremy Medovoy Partner

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Washington, D.C. T +1 202 857 2448 F fax +1 202 828 3348
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Jeremy advises clients on high-stakes energy enforcement and compliance matters before the Federal Energy Regulatory Commission (FERC), the Commodity Futures Trading Commission (CFTC), and the North American Electric Reliability Corporation (NERC). He brings firsthand experience in FERC investigations, audits, and surveillance and reliability inquiries, as well as related litigation stemming from such matters. Drawing on his broad senior leadership roles within FERC’s Office of Enforcement, including serving as FERC’s top ranking enforcement lawyer, Jeremy provides clients unique insight into the inner dynamics at play in agency enforcement matters, including the factors and priorities FERC and its staff consider in determining whether to pursue alleged violations and what sanctions and remedies to seek for them. He also assists clients in developing compliance programs tailored to their unique business operations in the energy markets.

As Deputy Director of FERC’s Office of Enforcement, and the office’s most senior-level attorney, Jeremy played a pivotal role in overseeing all aspects of the agency’s enforcement program, including investigations, enforcement actions, and federal court litigation involving alleged violations of federal energy laws. He led enforcement matters involving market manipulation, NERC’s reliability standards, and tariff compliance, working closely with other federal agencies and industry stakeholders to uphold the integrity of energy markets. Jeremy also managed FERC’s audit and accounting functions, providing oversight over audit scope areas and guidance on staff’s findings and recommendations in individual audits.

Before his appointment as Deputy Director, Jeremy held multiple leadership roles within FERC’s Office of Enforcement, including Deputy Director and Branch Chief in the Division of Investigations. Throughout his tenure, he was instrumental in shaping FERC’s enforcement policy and leading high-profile investigations and enforcement actions that have influenced the regulatory landscape. His experience spanned the electric, natural gas, and oil industries and involved all of FERC’s enforcement priority areas, including market manipulation, electric reliability, and infrastructure projects. He also worked in close coordination with staff at CFTC, NERC, the Department of Justice, and market monitoring units of the organized electric markets, gaining insight into the practices and priorities of these agencies. He began his career at FERC as an attorney in the Division of Investigations, where he gained significant experience conducting investigations, negotiating settlements, and advising on enforcement strategy. Jeremy’s deep understanding of FERC’s enforcement framework also enables him to provide strategic guidance on compliance, self-reporting, and risk mitigation.

Prior to joining FERC in 2009, Jeremy practiced law at an international law firm, representing clients in complex commercial litigation and civil and criminal government investigations. He also served as a law clerk to Judge Brook Hedge of the Superior Court of the District of Columbia.

Experience

While at FERC’s Office of Enforcement, Jeremy:

  • FERC Penalty Guidelines – Led the development of FERC’s Penalty Guidelines in 2010, establishing a framework for determining civil penalties for rule violations. Designed the model and policy framework, drafted the guidelines, presented them at a public FERC meeting, and led technical conferences to educate the industry. Served as the Commission’s subject matter expert on the guidelines. Jeremy is the leading authority on the Penalty Guidelines, with comprehensive knowledge of their provisions and a keen understanding of their applicability to all types of matters.
  • FERC Staff White Papers on Market Manipulation & Compliance – Drafted and presented the FERC Staff White Paper on Anti-Market Manipulation Enforcement Efforts and contributed to the White Paper on Effective Energy Trading Compliance Practices, providing industry guidance on the law of energy market manipulation and compliance best practices (2016).
  • Agency Witness on Key Enforcement Matters– Served as FERC’s first-ever Rule 30(b)(6) witness in a district court enforcement action, testifying on 39 topics related to market manipulation, penalty guidelines, tariff compliance, demand response markets, and FERC’s decision-making process (2017).
  • Revised Settlement Authority Process – Led reforms to FERC’s settlement authority process in 2024, transferring settlement negotiation authority from the Commission to the Office of Enforcement Director. Counseled leadership on the policy shift and led the Office of Enforcement’s implementation of the new process.
  • Natural Gas Policy Act (NGPA) Section 311 Audits – Led efforts to Integrate audits of NGPA Section 311 natural gas pipelines into the Office of Enforcement’s annual audit plan, expanding regulatory oversight (2023).
  • FERC Order Rescinding Notice of Alleged Violation Policy – Led implementation of FERC’s decision to rescind policy of issuing Notices of Alleged Violations during investigations, advising leadership on the policy implications (2019).
  • Market Manipulation Matters – Played a lead role on many of the most high-profile and complicated market manipulation investigations and litigations, contributing to the development and articulation of FERC’s main theories of fraud, including cross-market schemes, gaming, and misrepresentations.
  • Reliability Matters – Led or oversaw many of FERC’s largest reliability investigations and inquiries, including the joint FERC/NERC inquiry into the September 2011 Southwest blackout and resultant six investigations, as well as the joint inquiries into winter storms Uri and Elliott.

In his prior private practice experience, Jeremy:

  • False Claims Act Investigation – Represented large trading company in connection with Department of Justice investigation into potential False Claims Act violations related to sales of allegedly defective body armor.
  • Off-Label Marketing Investigation – Represented pharmaceutical company in connection with Department of Justice investigation into alleged civil and criminal violations under the False Claims Act and the Food, Drug, and Cosmetic Act for alleged marketing of off-label drug use.
  • Patent Infringement Litigation – Represented multinational electronics company in patent infringement jury trial related to semiconductor memory technology in computers (Matsushita Electric Industrial Co. v. Samsung Electronics Co., Civ. No. 02-336 (D.N.J. 2006)).

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