February 4, 2023

Volume XIII, Number 35

Anne M. Termine

Drawing on nearly 20 years of CFTC experience, Anne Termine represents stakeholders in the commodities, derivatives and cryptocurrency markets in connection with internal investigations, regulatory enforcement and litigation matters. She also helps clients with regulatory advocacy before various agencies and in developing practical compliance and other policies and procedures tailored to their individual business needs.

From October 2003 to August 2016, Anne was a chief trial attorney in the US Commodity Futures Trading Commission’s (CFTC) Division of Enforcement, where she investigated and prosecuted alleged violations of federal laws related to commodities, futures, options, swaps and other derivatives. She led investigations involving the attempted manipulation and false reporting of natural gas and crude oil prices, multi-million dollar Ponzi and other fraud schemes, and the illegal operations of event-based or prediction markets. Anne notably was the architect and manager of the landmark CFTC enforcement program involving the manipulation and false reporting of LIBOR, Euribor and TIBOR. She led negotiations with nine global financial institutions, imposing $2.8 billion penalties in the sprawling international investigation that involved regulatory and law enforcement agencies across Europe and Asia, multiple divisions of the US Department of Justice, and a coalition of more than 40 state attorneys general. In recognition of her leadership handling the LIBOR investigations, she received the Chairman’s Award for Excellence, the CFTC’s highest award. 

Before joining the CFTC, Anne was a senior assistant district attorney in the Orleans Parish District Attorney’s Office. She tried more than 140 jury and non-jury trials, including several first-degree and second-degree murder cases.

Articles in the National Law Review database by Anne M. Termine