Jonathan T. Ammons

Jon is a partner in Reed Smith’s Energy & Natural Resources Industry Group, focusing on regulatory matters, government investigations, and transactional issues related to commodities, derivatives, and digital assets.

For nearly 15 years, Jon has represented U.S. and non-U.S. clients in responding to government investigations and disciplinary and enforcement actions brought by the Commodity Futures Trading Commission (CFTC), futures exchanges, the National Futures Association (NFA), the Federal Energy Regulatory Commission (FERC), the Securities and Exchange Commission (SEC), and the Financial Industry Regulatory Authority (FINRA). Among other things, Jon has represented clients in matters related to disruptive trading practices, manipulation, fraud, and fiduciary duties. He also regularly conducts internal investigations for clients related to potential violations of the Commodity Exchange Act, the Federal Power Act, the Natural Gas Act, and securities laws.

Experience

Representative matters

Represented a non-U.S. company in connection with a CFTC enforcement matter related to disruptive trading practices.

Conducted an internal investigation for a U.S. trading platform in connection with swap data reporting requirements.

Represented a U.S. energy company in connection with a disciplinary action from a futures exchange, and subsequent CFTC and DOJ investigations of crude oil futures trading activity and potential disruptive trading and spoofing.

Represented a non-U.S. company in connection with a CFTC enforcement matter related to disruptive trading practices.

Conducted an internal investigation for a U.S. trading platform in connection with swap data reporting requirements.

Represented a U.S. based utility company in connection with an inquiry from a U.S. futures exchange regarding natural gas futures trading and compliance with applicable position limit rules and regulations.

Represented a U.S. swap dealer in connection with an enforcement action brought by the CFTC for failing to deal with a counterparty in a fair and balanced manner.

Represented a non-U.S. trading firm in connection with a CME disciplinary action for spoofing.

Represented a registered investment adviser in connection with an SEC enforcement matter for allegedly violating fiduciary duties and regulatory requirements, ultimately obtaining confirmation from SEC staff that they would pursue no further action.

Represented a broker-dealer registered representative in connection with an enforcement action brought by the SEC for accepting orders from non-retail clients during retail order periods for new issue municipal bonds.

Advised a wide range of derivatives market participants regarding regulations promulgated pursuant to Title VII of Dodd-Frank; assisted with the development of operational systems for internal and external business conduct rules, clearing, collateral, reporting of trade data, trading documentation, disclosures and client onboarding.

Drafted requests for no-action relief, exemptive relief and interpretive guidance for dealers, end-users and technology platforms in connection with rules promulgated pursuant to Dodd-Frank.

Drafted compliance policies and procedures for dealers and end-users in connection with derivatives businesses.

Counseled electronic trading platforms in connection with registration and operations of SEFs in the foreign exchange, credit and interest rate asset classes; drafted multiple comment letters regarding SEF trading and registration requirements; prepared all documentation for SEF registrations.

Drafted product specifications for NDFs and FX options to be traded on foreign exchange SEFs.

Advised U.S. and non-U.S. funds on access requirements for non-U.S. cryptocurrency trading platforms.

Advised clients on token offerings under SAFT Agreements and pursuant to U.S. securities laws.

Advised a global futures exchange and clearinghouse regarding the creation of various new futures contracts, including a contract based on a cryptocurrency and a contract based on a broad-based non-U.S. stock index.

Assisted a global futures exchange and clearinghouse with regulatory approvals associated with commingling swaps and futures in cleared swaps accounts.

Advised a digital asset company on establishment of a digital asset market infrastructure platform.

Assisted a non-U.S. clearing organization with preparation of an application to become an exempt DCO.

Assisted a non-U.S. futures exchange and clearinghouse with registration as an Approved Exchange and Approved Clearing House in Singapore.

Advised a global futures exchange and clearinghouse on the preparation, implementation, and regulatory approval of a new margin framework for futures and options contracts.

Advised a global futures exchange and clearinghouse on the creation, implementation, and regulatory approval process for a new category of direct clearing membership.

Represented numerous hedge funds and private funds in connection with new registration and compliance obligations applicable to commodity pool operators and commodity trading advisors.

Represented an investment bank in connection with the application of commodity pool operator registration requirements to CLOs and other securitizations; drafted requests for no-action relief.

Advised domestic and foreign financial institutions in connection with registration and compliance obligations applicable to introducing brokers.