Tony focuses on commodities, securities and related derivatives enforcement defense, follow-on litigation, compliance and regulatory advisory matters, involving the Commodity Futures Trading Commission (CFTC), the Federal Trade Commission, the Federal Energy Regulatory Commission, other federal and state regulatory agencies and criminal authorities, the UK Financial Conduct Authority and the European Commission. 

Tony represents a broad range of market participants, including global financial institutions, major integrated oil companies, agribusiness companies, global trading companies, hedge funds, asset managers, energy marketers, futures commission merchants and exchanges.

Prior to returning to private practice in 2007, Tony served as a Chief Trial Attorney and Counsel to the Director in the Division of Enforcement of the CFTC. He was responsible for the Division’s investigations of numerous energy and power marketing companies relating to price reporting in the natural gas markets. He also played a central role in the Commission’s subpoena enforcement actions against natural gas price index compilers, involving First Amendment “Reporter’s Privilege” issues, and was central in the Commission’s defense of its exercise of jurisdiction over false reporting in the natural gas markets pursuant to the Commodity Exchange Act.

Tony previously served as a member of the CFTC’s Energy and Environmental Markets Advisory Committee, and the Law & Compliance Executive Committee of the Futures Industry Association.

Tony has been recognized by Chambers USA as a stand-out in this area. He has also been chosen by his peers for inclusion in The Best Lawyers in America four consecutive years for his high caliber of work in derivatives and futures law, and he has been honored by The Legal 500 United States as a leader in energy law and securities litigation. A frequent speaker and author, he has written on commodities and derivatives legal issues.

Expertise

Industries

Published Work

  • “CFTC Announces Proposed Guidance and a Request for Comments Regarding Voluntary Carbon Credit Derivative Contracts,” Allen & Overy update, December 2023
  • "Crypto-tunities: Transaction strategies in the challenging crypto markets", Allen & Overy update, July 13, 2022
  • "Insider Trading Enforcement Intensifies Across Markets and Regulators", New York Law Journal, Vol. 261-No. 18 (Jan. 28, 2019), with Eugene Ingoglia and Chelsea Pizzola
  • "Commodity Futures Trading Commission Enforcement", Global Competition Review: The Guide to Energy Market Manipulation (March 2018)
  • "Data Privacy & Transfer in Investigations," Global Investigations Review (November 3, 2017), with Sara Lenet and Jonathan Flynn
  • "Inside the New Forex Market Code of Conduct", Law360 (June 9, 2016), with Gregory Mocek, Jonathan Flynn, and Jorge Pesok
  • "Regulators are Widening the Spoofing Net", Law360 (May 26, 2016), with Gregory Mocek, Paul Pantano, and Jonathan Flynn
  • "Compliance Departments Must Continue to Evolve as Regulators Refine Their Approach to Spoofing", The National Law Review (May 5, 2016), with Gregory Mocek, Paul Pantano, and Jonathan Flynn

Speaking Engagements

  • Panelist, Allen & Overy symposium, “AI Enforcement and Corporate Compliance Programs,” February 26, 2024
  • Panelist, Futures Industry Association webinar, “Trust but Verify, New expectations in regulatory enforcement cases and the evolving role of post-settlement obligations,” February 15, 2024
  • Panelist, Futures Industry Association, Law & Compliance 2023, “Reporting & Recordkeeping: Is Technology a Blessing or Curse,” April 27, 2023
  • Panelist, Futures Industry Association webinar, “New Frontiers in Recordkeeping and Compliance,” October 13, 2022
  • Panelist, “Multi-jurisdiction Enforcement Litigation—Lessons Learned,” ISDA Symposium on CFTC Enforcement, New York, NY, October 1, 2015
  • Panelist, “Energy Futures Regulation,” UT Law 14th Annual Gas and Power Institute, Houston, TX, September 10-11, 2015
  • Panelist, “Trends in Enforcement and Related Litigation,” American Bar Association’s Derivatives and Futures Law Committee Meeting, January 22-24, 2015
  • Panelist, “Impact of Changes in Futures Regulation on Execution and Compliance,” Oilseed & Grain Trade Summit, Minneapolis, MN, October 21-23, 2013

Qualifications

Admissions

Registered Foreign Lawyer, England and Wales, 2024

U.S. Court of Appeals, 1st Circuit

U.S. District Court, District of Massachusetts

U.S. Supreme Court

Commonwealth of Massachusetts

District of Columbia

Academic

J.D., cum laude, Vermont Law School

M.S.L., cum laude, Vermont Law School

B.A., cum laude, Bowdoin College

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Disclaimer
A&O Shearman was formed on May 1, 2024 by the combination of Shearman & Sterling LLP and Allen & Overy LLP and their respective affiliates (the legacy firms). Any matters referred to above may include matters undertaken by one or more of the legacy firms rather than A&O Shearman.