Overview
As a member of Steptoe's Government Affairs & Public Policy and the Financial Innovation & Regulation practices, Ryan Hayden advises financial institutions, commodity market participants, financial service providers, and recent market entrants on a range of regulatory and transactional matters, including legal and compliance requirements related to derivatives. He counsels clients on the Commodity Exchange Act and the Dodd-Frank Act, including Title VII and swaps and security-based swaps. Ryan frequently engages with US financial regulators in advocacy efforts on behalf of clients, ranging from registration and seeking relief to advising on enforcement matters. His Commodity Futures Trading Commission (CFTC) enforcement work has included trade reporting, documentation, recordkeeping, surveillance, compliance and supervisory programs, business conduct standards, manipulation, and other rule areas and requirements.
Clients rely on Ryan's comprehensive understanding of legal and regulatory issues and seek his practical, accessible legal advice borne from holding senior-level in-house legal and compliance positions and experience working across asset classes. Prior to joining Steptoe, Ryan worked as in-house counsel to two international commodity market participants and a global financial institution, also serving as Chief Compliance Officer to US and non-US CFTC registrants. While in-house, Ryan’s practice focused on derivatives, securities, and banking regulatory and transactional advice, often counseling new businesses and trading ventures and advising on compliant business structuring and strategy.
Ryan is a frequent speaker on financial regulatory matters at industry trade group events. Ryan also serves as Co-Chair of the Derivatives Subcommittee of the DC Bar Corporation, Finance, and Securities Law Community. He began his financial services career at the CFTC in Commissioner Bart Chilton's office and at the US Senate Banking Committee.
- District of Columbia
- Illinois
- Maryland
- J.D., American University, Washington College of Law, 2013, Vice President, Student Bar Association
- B.S., University of Mary Washington, 2009, cum laude, Business Administration and English
Areas of Work
Speaking Engagements
- "How CFTC Regulation Impacts Hedgers & Municipalities," 2024 APGA Gas Supply Conference, May 8, 2024
- "From Line 1 to Supervisors: How to Create (and Maintain) a Culture of Compliance," FIA Law & Compliance Division Conference, April 25, 2024
- "Fireside Chat with CFTC Commissioner Caroline Pham," DC Bar Association, April 17, 2024
- Registrants: CPO/CTA, FCM, IB, Swap Dealer, SBSD, ABA Derivatives and Futures Law Committee Winter Meeting 2024, January 27, 2024
- "Law & Compliance – Sifting Through the Regulatory Developments," FIA Futures & Options Expo, October 3, 2023
- "Worst Day in the Career of a FCM In-House Attorney (Ethics Panel)," FIA Law & Compliance Conference 2023, April 27 2023
- "Compliance and Operations Hot Topics," FIA Forum: Commodities 2022, June 22, 2022
News & Publications
Press Releases
April 29, 2025
Blockchain Blog
Deputy Attorney General Memorandum: "Ending Regulation by Prosecution"
April 11, 2025
By: Marlon Paz, Andrew C. Adams, Evan T. Abrams, Galen Kast, Ryan Hayden, Sophia Breggia
Publications
CFTC Enforces Traditional Commodities Laws in Environmental, Voluntary Carbon Markets
Futures & Derivatives Law Report
February 14, 2025
By: Ryan Hayden, Micah S. Green, Daniel A. Mullen, Sophia Breggia, Vito Arethusa, Nathaniel Sans
Press Releases
Steptoe Advises KOR Reporting on Security-Based Swap Data Repository Application
November 6, 2024
Publications
October 2024
Publications
Carbon Offset Case A Win For CFTC Enviro Fraud Task Force
Law360
August 27, 2024
By: Ryan Hayden, Daniel A. Mullen, Coy Garrison, Micah S. Green, Vito Arethusa
Client Alerts
CFTC "Heats Up" Pursuit of Bad Environmental Actors Involved in Carbon Offsets
August 2, 2024
By: Ryan Hayden, Daniel A. Mullen, Coy Garrison, Micah S. Green, Vito Arethusa
Client Alerts
June 13, 2024
By: Ryan Hayden, Micah S. Green, Alexandra C. Scheibe, Richard Shilts, Michael V. Dunn
Events
Webinars
Quarterly Investigations & Enforcement Update
April 24, 2025
Speakers: Jason Abel, Akita Adkins, Iris E. Bennett, Christopher R. Conte, Amba M. Datta, Ryan Hayden, Michelle Kallen, Patrick F. Linehan, Michael Campion Miller, Zoe Osborne, Wendy Wysong
Webinars
Quarterly Investigations & Enforcement Update
January 28, 2025
Speakers: Jason Abel, Lee Berger, Christopher R. Conte, Amba M. Datta, Ryan Hayden, Gregory S. McCue, Michael Campion Miller, Zoe Osborne, Wendy Wysong
Webinars
Quarterly Investigations & Enforcement Update
October 30, 2024
Speakers: Jason Abel, Akita Adkins, Iris E. Bennett, Amba M. Datta, Sandra Hanna, Ryan Hayden, Patrick F. Linehan, Michael Campion Miller, Zoe Osborne, Wendy Wysong
Seminars & Events
Developing an OTC Derivatives Trading Desk
October 1, 2024
Speakers: Alexandra C. Scheibe, Ryan Hayden, Daniel A. Mullen
Previous Employment
- Senior Lawyer, Cargill, Incorporated (2021-2022)
- Senior Legal Counsel/Chief Compliance Officer, E D & F Man Capital Markets (2018-2021)
- Legal Counsel, Vice President, Northern Trust Corporation (2014-2018)
- Majority Staff, US Senate Committee on Banking, Housing and Urban Affairs (2013)
- Legal and Policy Intern for Commissioner Bart Chilton, US Commodity Futures Trading Commission (2012-2013)