High Gas Prices, Heightened Enforcement Risk - DOJ and FTC Call on State Attorneys General to Investigate Petroleum Markets

Short summary

DOJ and the FTC issued a joint letter urging state attorneys general to investigate petroleum markets for price fixing, market manipulation, and other unlawful conduct contributing to high gas prices. The announcement signals coordinated federal-state enforcement risk across the petroleum supply chain. Energy companies should prepare to contemporaneously document business justifications for pricing decisions to defend against overlapping scrutiny.

• •DOJ and FTC urging state AGs to investigate petroleum market pricing conduct
• •Federal-state coordination increases enforcement risk across the supply chain
• •Companies should document business rationales for pricing decisions proactively

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