Enterprise Products just got fined $100K for having multiple wash trades over a 10 month in 2016. The trades were in multiple energy contracts and they were trades between accounts with the same beneficial owner (looks like trades in the exchange across books but not the same account - which would have been a cross trade.). The notice also cited lack of training of staff that contributed to the occurrences.
We like to think of market regulation fines as "parking tickets" - something of a nuisance. The problem is, if left unaddressed, they can turn into speeding tickets. Surveillance of manipulation isn't the only thing compliance needs to cover - compliance with basic market regulations is important too. The notice is here - https://www.cmegroup.com/notices/disciplinary/2018/09/NYMEX-17-0641-BC-1-ENTERPRISE-PRODUCTS-PARTNERS-LP.html#pageNumber=1
DCM LLC can help with compliance training and surveillance needs. We would be happy to speak with you.