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Anne M. Termine
Of Counsel
Washington +1 202 662 5827 atermine@cov.com Download V-card

Anne Termine is a member of the firm’s Global Futures and Derivatives Practice and leads the Derivatives Enforcement Team. She is also a member of the white collar defense and investigations practice. Ms. Termine advises clients in handling internal investigations and regulatory enforcement inquiries related to the derivatives markets and the cryptocurrency markets.

Prior to joining Covington, Ms. Termine was a Chief Trial Attorney in the U.S. Commodity Futures Trading Commission's (CFTC) Division of Enforcement, where she was responsible for investigating and prosecuting alleged violations of federal laws dealing with commodities, futures, options, swaps, and other derivatives. While in this role, Ms. Termine designed and led the CFTC’s landmark enforcement program involving the manipulation and false reporting of LIBOR, Euribor and TIBOR - critical, international benchmark interest rates. She spearheaded negotiations that resulted in settlements with nine international financial institutions, imposing penalties totaling over $2.8 billion. In managing this massive, global investigation, Ms. Termine was instrumental in developing relationships and coordinating with diverse foreign regulatory and law enforcement agencies throughout Europe and Asia, as well as with divisions of the United States Department of Justice and a coalition of over 40 State Attorneys General. She received the Chairman’s Award for Excellence, the CFTC’s highest award, for her work on and leadership in handling the LIBOR investigations.

  • Advise Coinbase, Inc. on financial services regulations, including the regulatory requirements of the CFTC related to cryptocurrency.
  • Represent several individuals and companies in exchange and CFTC enforcement matters related to trade practice violations, failure to supervise, and market manipulation.
  • Advise multiple swap dealers on compliance with the CFTC’s regulations, including rules related to external business conduct standards and the trading of swaps on SEFs.
  • Advise multiple derivatives market participants, including financial institutions, on compliance with and training of CFTC regulations, including policies and procedures related to futures and swaps trading and clearing and potential enforcement implications.
  • Advise multiple derivatives market participants regarding the regulatory requirements for domestic and international derivatives activities, including swap product analysis and swap dealer registration requirements.

Previous Experience

  • U.S. Commodity Futures Trading Commission, Chief Trial Attorney, Division of Enforcement
  • Orleans Parish District Attorney’s Office, Senior Assistant District Attorney
  • Recipient of Chairman’s Award for Excellence, CFTC’s highest award