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Sarah V. Riddell

Sarah Riddell is a partner and a member of the firm’s Asset Management and Investment Funds practice. As a former regulator, Sarah has insight that enables her to be a trusted advisor to clients. She frequently speaks at conferences and engages in thought leadership on emerging issues important to the derivatives industry.

Sarah advises a broad range of market participants on regulatory matters. She assists US and international futures and swap exchanges, clearing houses, and financial institutions on Commodity Futures Trading Commission (CFTC) registration, compliance, and cross-border issues. She also advises exchange-traded fund issuers, private fund managers, futures commission merchants and swap dealers with CFTC and National Futures Association (NFA) with becoming registered with the CFTC, developing compliance programs, and successfully undergoing regulatory examinations. Sarah also works with trade associations, particularly when the CFTC and Securities and Exchange Commission propose new or amended regulations.

Sarah advises a range of clients on regulatory matters involving digital assets, including helping institutional investors conduct due diligence on investments, analyzing the legal and regulatory status of a digital asset, and advising issuers on state law and regulation, including the applicability of the New York State Department of Financial Services (NYDFS) BitLicense regulation and federal and state laws and regulations.

Sarah’s experience extends to cybersecurity issues, with hands-on experience assisting clients that have experienced cybersecurity attacks or been affected by service providers’ outages. She has provided guidance during cybersecurity investigations and assessments of forensic analyses and has drafted and submitted notifications to customers and regulatory agencies under various states’ requirements, the NFA’s Information Systems Security Program interpretive notice, and the NYDFS Cybersecurity Regulation.

Prior to joining the firm, Sarah was of counsel with another global law firm, where she served as co-leader of its digital assets group. Having also served as a lawyer with the CFTC, Sarah has extensive and specific experience with CFTC and Dodd-Frank Act compliance regulation. While at the CFTC, Sarah worked on the customer protection rulemaking and the CFTC’s first examinations of systemically important derivatives clearing organizations with the Board of Governors of the Federal Reserve System and the SEC pursuant to the Dodd-Frank Act.

  • Member, Futures Industry Association Law and Compliance Division (Former Executive Committee Member)
  • Co-Chair, Chicago Bar Association Futures and Derivatives Law Committee
  • Member, American Bar Association
  • Member, Women in Listed Derivatives (WILD)
  • Panelist, “Registrants (CPO/CTA, FCM, IB, Swap Dealer, SBSD)” American Bar Association Derivatives and Futures Law Winter Committee Meeting, 2024
  • Panelist, “To Clear or Not to Clear? Which Direction Are Regulators Going?” Futures Industry Association Law and Compliance Division Conference, 2024
  • Panelist, “Introduction to Blockchain,” Jundacella Corporate Counsel Group (JCCG), Miami, 2023 
  • Moderator, “CPO/CTA Issues,” Futures Industry Association Law and Compliance Division Conference, 2023
  • Speaker, Chicago Chief Compliance Officer Roundtable, 2019 and 2023
  • Panelist, Managed Funds Association’s Legal and Compliance Conference–New York, 2022 
  • Panelist, “FCM vs. Swap Dealer,” Futures Industry Association Law and Compliance Division Conference, 2022
  • Panelist, FIA Operations Americas Division: How We Keep Futures Markets Operational Through World Events, 2022
  • Panelist, “Deliveries 101,” Futures Industry Association Law and Compliance Division Conference, 2021
  • Panelist, “Clearing 101,” Futures Industry Association Law and Compliance Division Conference, 2020
  • Panelist, “Tearing Down the Cross-Border Wall,” Futures Industry Association Law and Compliance Division Conference, 2019
  • Erin Martin and Sarah Riddell, The ESG Entanglement: Policies and Laws Affecting Futures Intermediaries, 44 FUTURES & DERIVATIVES REPORT 1, June 2024
  • Frederick L. Block, Alyse J. Rivett, Sarah V. Riddell, and Madeleine Ayer, SEC V. The Crypto Industry–Tracking the SEC’s Ongoing Litigation Against Digital Asset Exchanges, 57 THE REVIEW OF SECURITIES & COMMODITIES REGULATION 57, March 2024
  • Robin Nunn, Steven Lightstone, and Sarah Riddell, What 2021 Has In Store for Stablecoin, 4 THE JOURNAL OF ROBOTICS, ARTIFICIAL INTELLIGENCE & LAW 3, May-June 2021 
  • Michael Philipp, Akshay Belani, Christine Lombardo, and Sarah Riddell, Recordkeeping: Recent Rule Amendments and Other Developments, 51 THE REVIEW OF SECURITIES & COMMODITIES REGULATION 5, 7 March 2018 
  • Mark Krotoski, Charles Horn, and Sarah Riddell, NYDFS: “First-In-The-Nation” Cybersecurity Proposal, 19 WALL STREET LAWYER 10, October 2016 
  • Author, An Overview and Analysis of the Consumer Financial Protection Bureau, 12 ENGAGE 56, 2011 (Also available on Westlaw.)
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