Anna R. Biegelsen

Senior Counsel
Norton Rose Fulbright US LLP

Anna R. Biegelsen

Anna R. Biegelsen

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Biography

Anna advises energy marketing and trading firms, financial institutions, and other clients participating in US energy markets on regulatory, enforcement, and compliance issues. She has helped clients navigate FERC and CFTC enforcement inquiries on a variety of issues, ranging from alleged market manipulation to alleged violation of FERC orders. Anna has successfully resolved non-public investigations by both FERC and CFTC, and has successfully obtained favorable outcomes during the public stages of such investigations, including a FERC decision not to pursue further action against an individual defendant at the Order to Show Cause phase of a market manipulation investigation.  

In addition to her work in enforcement investigations, Anna advises clients on regulatory matters involving FERC and CFTC regulations, including compliance with requirements applicable to market-based rate sellers and other FERC-regulated market participants, regulatory requirements related to acquisition and disposition of FERC-jurisdictional facilities, application of CFTC's registration, reporting, and disclosure requirements, and numerous other topics.  She has also successfully represented clients in regulatory proceedings before FERC, including complaint proceedings, section 203 application proceedings, market-based rate applications and related proceedings, RTO/ISO tariff amendment proceedings, and others. 

Additionally, Anna works with clients to implement compliance programs, and to develop trainings on the requirements of the Federal Power Act, the Natural Gas Act, the Commodity Exchange Act and FERC's and CFTC's regulations. 

Anna is proud to have been recognized as a rising star and recommended lawyer in Energy regulation: conventional power by The Legal 500, and was recently listed on The Best Lawyers in America, Ones to Watch for Energy Law.


Professional experience

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JD, Harvard Law School, 2012
BA, St. John's College, 2008

While in law school, Anna participated as subscriptions manager and a senior editor of the Harvard Journal of Law and Public Policy. Anna also participated in a clinical program at the U.S. Attorney's Office in Boston, as a law clerk in the Drug Task Force.

  • District of Columbia Bar
  • Florida State Bar
  • FERC enforcement matters:
    • Represented owner and trader in FERC Enforcement action regarding up-to congestion trading in PJM.
    • Represented senior manager of generation owner in FERC Enforcement investigation of bidding practices.
    • Represented client in FERC Enforcement investigation of qualification and sales in ISO-administered capacity auction, which resulted in a favorable finding of no violation.
    • Represented client in FERC Enforcement investigation of adherence to FERC order.
    • Represented client as witness in FERC Enforcement investigation of another market participant's FTR activity and related default.
  • CFTC enforcement matters:
    • Represented client in CFTC investigation of trading in agricultural commodities.
    • Represented non-US client in CFTC investigation of US commodity trading activity.
    • Represented client in CFTC investigation of exchange-for-related-positions activity.
    • Represented client as witness in CFTC investigation of conduct by other market participants.
    • Representative Energy Regulatory/Compliance Experience:
    • Drafted successful petition for declaratory order seeking interpretation of RTO tariff requirements.
    • Conducted regulatory due diligence for generation asset acquisitions.
    • Drafted Federal Power Act section 203 applications and related regulatory filings.
    • Drafted applications for market based-rate authorization and related regulatory filings.
    • Counseled clients on capacity market design issues and proposed changes. 
    • Advised clients on issues related to CFTC registration requirements and related exemptions.
    • Advised clients on cross-border application of CFTC regulatory requirements.
    • Advised client on FERC Standards of Conduct compliance for transmission providers. 
    • Review financial institution's policies and procedures for compliance with US regulatory requirements.
    • Developed compliance training materials and compliance manuals for power marketer on FERC, CFTC, and DOE regulations. 
    • Developed compliance training materials and compliance manuals on FERC Standards of Conduct and FERC/CFTC anti-manipulation regulations.  
  • Legal 500 US, Rising Star, Energy regulation: conventional power, The Legal 500, 2019 – 2022
  • Legal 500 US, Recommended Lawyer, Energy regulation: conventional power, The Legal 500, 2019 – 2021
  • The Best Lawyers in America - Energy Law, Best Lawyers, 2021 – 2022