Daniel J. Grimm served as Senior Counsel to the Chairman of the U.S. Commodity Futures Trading Commission (CFTC). In this his role, he advised former CFTC Chairman Heath Tarbert on issues including swap data reporting, capital requirements for swap dealers, the registration of new markets and products, uncleared margin and clearing requirements for derivatives, regulatory relief involving COVID-19 and Brexit, and a variety of litigation and enforcement matters.
Professor Grimm was previously a Senior Trial Attorney in the CFTC’s Division of Enforcement, where he investigated and prosecuted violations of the Commodity Exchange Act involving cybersecurity and data protection, digital assets, anti-money laundering, market manipulation, and fraud. He pursued numerous parallel enforcement matters with the Department of Justice, the Securities and Exchange Commission, the Federal Bureau of Investigation, and other authorities. In 2019, he assisted the Enforcement Director in launching the CFTC’s foreign corruption enforcement program. Cases for which he was responsible have resulted in hundreds of millions of dollars in court-ordered judgments and settlements.
Prior to joining the CFTC, Professor Grimm practiced law at Sullivan & Cromwell in Washington, DC, where he focused on litigation, enforcement, and advisory matters involving derivatives, securities, the Foreign Corrupt Practices Act (FCPA), anti-money laundering, and U.S. economic and trade sanctions.
Professor Grimm’s research has addressed financial regulation, the FCPA, and emerging technologies, and has appeared in the University of Pennsylvania Journal of Business Law, the NYU Journal of Law & Business, and the American University Law Review, among others. He joined the Georgetown Law adjunct faculty in 2018.
