Sarah V. Riddell

Of Counsel

Leveraging her experience as a lawyer at the US Commodity Futures Trading Commission (CFTC), Sarah V. Riddell advises domestic and foreign exchanges, derivatives clearing organizations, swap execution facilities, and other financial institutions on a broad range of regulatory matters, including CFTC registration and compliance. Sarah also assists hedge fund and swap dealer clients with CFTC and National Futures Association (NFA) registration, compliance, and examination questions. While at the CFTC, Sarah worked on Dodd-Frank-related rulemakings and participated in examinations of derivatives clearing organizations, including those designated as systemically important.

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Extended Profile

In addition, Sarah helps clients understand and comply with the NFA’s Information Systems Security Program interpretive notice and the New York Department of Financial Services (NYDFS) Cybersecurity Regulation, as well as related cybersecurity questions. Sarah has assisted clients who have experienced cybersecurity attacks, assisted in the cybersecurity investigations and assessments of forensic analyses about the incident, and has drafted and submitted notifications to customers and regulatory agencies. Sarah also advises funds, digital wallet businesses, and exchanges that invest in or issue crypto assets on regulatory issues, including the applicability of NYDFS regulations and federal and state laws and regulations.

Selected Representations

Represented companies in complying with standards under the New York Department of Financial Services Cybersecurity Regulation
Represented companies in responding to data security incidents
Advise international clearing house on CFTC matters, including the investment of customer funds and CFTC-compliant documentation for such investments.
Advise clients, including global investment management firms, on position limits and successfully obtaining exemptions from exchange-established position limits.
Counsel foreign exchanges on CFTC-compliant offerings of their contracts to US persons.
Assist clients with registering with the CFTC as a foreign board of trade, designated contract market, or swap execution facility.