Peter A. Varlan

Peter Varlan advises clients on regulatory, compliance, enforcement and litigation matters, with a particular focus on the commodities and derivatives markets. He represents financial institutions, other corporations and individuals in criminal and civil investigations involving the Department of Justice (DOJ), the Commodity Futures Trading Commission (CFTC), the Securities and Exchange Commission (SEC) and other government authorities and self-regulatory organizations. Mr. Varlan also regularly counsels clients on regulatory compliance and transactional matters relating to the futures, swaps and digital assets markets.

Mr. Varlan’s representations have included, among others:

• swap dealers and security-based swap dealers in CFTC and SEC investigations concerning swaps reporting
• a precious metals trader in parallel criminal and civil actions brought by the DOJ and CFTC for alleged spoofing, attempted price manipulation, fraud and conspiracy
• the creators of a non-fungible token (NFT) in reaching a favorable settlement of an SEC investigation concerning the offering of unregistered securities
• a digital assets company in a CFTC investigation
• Pfizer in a dispute with the SEC and related litigation over undistributed funds stemming from an insider trading settlement in which the company collected $29 million
• a military parts manufacturer in a bribery probe by the U.S. Attorney’s Office for the Southern District of New York
• Greystar in antitrust investigations and litigations brought by the DOJ and state attorneys general alleging that multifamily property managers inflated rents through the use of revenue management software
• a swap dealer and futures commission merchant in reaching a favorable settlement with the CFTC concerning supervisory systems
• an internal investigation concerning employee misconduct for a professional sports team
• an energy company in recovering restitution resulting from a kickback scheme
• swap dealers and security-based swap dealers in responding to National Futures Association (NFA) and SEC examinations