Sarah V. Riddell

Of Counsel

Leveraging her experience as a lawyer at the US Commodity Futures Trading Commission (CFTC), Sarah V. Riddell advises US and international exchanges, derivatives clearing organizations, swap execution facilities, and financial institutions on a broad range of regulatory matters, including CFTC registration and compliance. Sarah assists private fund managers, exchange-traded fund issuers, futures commission merchants, and swap dealers with CFTC and National Futures Association (NFA) registration, compliance, and examination matters. Sarah is the co-leader of the firm’s Digital Assets Working Group.

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All Things FinReg

Extended Profile

Sarah advises funds, digital wallet businesses, and exchanges that invest in or issue digital assets on regulatory issues, including the applicability of the New York State Department of Financial Services (NYDFS) BitLicense regulation and federal and state laws and regulations. Sarah also helps clients understand and comply with the NFA’s Information Systems Security Program interpretive notice and the NYDFS Cybersecurity Regulation. Sarah has hands-on experience assisting clients that have experienced cybersecurity attacks, including providing guidance during cybersecurity investigations and assessments of forensic analyses, and she has drafted and submitted notifications to customers and regulatory agencies.

While a lawyer at the CFTC, Sarah worked on rulemakings related to the Dodd-Frank Act and participated in examinations of derivatives clearing organizations, including those designated as systemically important.

Selected Representations

Assisted clients with registering with the CFTC as a foreign board of trade, designated contract market, or swap execution facility
Analyzed exchange token offerings for compliance with the Commodity Exchange Act and provided strategic advice on digital asset investments
Advised an international clearing house on CFTC matters, including the investment of customer funds and CFTC-compliant documentation for such investments
Advised clients, including global investment management firms, on complying with position limits and successfully obtaining exemptions from exchange-established position limits
Counseled non-US exchanges on CFTC-compliant offerings of their contracts to US persons
Represented companies in responding to data security incidents and reporting incidents to the US Securities and Exchange Commission, NFA, and NYDFS