Sarah V. Riddell

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.

• 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