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Helping clients navigate complex financial transactions, Allison Baker Shealy draws on her extensive experience on both sides of the enforcement aisle to guide them through the complicated national and international regulatory environment.  Whether it is futures, Forex, swaps, securities, cryptocurrencies or complex lending and/or organizational arrangements, she is able to quickly get to the heart of the matter and work with clients for the best possible resolution.  Regardless of the size or complexity of a matter, clients receive the same thorough and effective representation.

As a Senior Trial Attorney in the U.S. Commodity Futures Trading Commission’s Division of Enforcement, Allison investigated and litigated matters involving manipulation, spoofing, wash trading, solicitation fraud, misappropriation of customer funds, commodity pool fraud, Ponzi schemes, and unauthorized trading.  She also worked with futures commission merchants (“FCMs”) and retail foreign exchange dealers (“RFEDs”) to bring them into compliance with the CFTC’s requirements regarding regulatory capital and segregation of customer funds and to engage in undertakings to reduce the likelihood of such violations in the future.  While at the CFTC, Allison worked on such precedent setting matters as the first case charging a manipulative device and the first case bringing charges pursuant to the business conduct standards for swap dealers under the Dodd-Frank Act, as well as one of the first cases to charge an RFED with a failure to supervise its employees and agents.

In difficult situations, clients appreciate that Allison has experience with all aspects of representation and is able to provide legal and strategic guidance on matters involving general regulatory compliance, criminal investigations, private civil lawsuits, government enforcement actions, Congressional investigations, as well as having conducted numerous internal investigations.  As a government attorney, she worked successfully on cooperative enforcement matters with the Securities and Exchange Commission, the Department of Justice, the FBI, the Office of the Comptroller of the Currency, Secret Service, the United Kingdom’s Financial Conduct Authority, Public Company Accounting Oversight Board, National Futures Association, and various state corporation commissions.

Professional & Community Affiliations

  • Maryland Volunteer Lawyers Service, Board of Directors
  • National Association of Criminal Defense Lawyers, Member
  • Women’s White Collar Defense Association, Member
  • Women’s Bar Association, Member
  • CFTC Graduates Society, Member
  • Advise company creating unique cryptocurrencies regarding CFTC compliance.
  • Advise individual regarding legal implications of sale of cryptocurrencies on peer-to-peer platform.
  • Investigated trading in swap indices by “London Whale” and negotiated $100 million settlement.
  • Obtained judgment as a result of discovery violations against trader who obtained unauthorized access to Luxemburg based investment firm and engaged in wash trading. 
  • Obtained favorable judgments in $35 million ponzi scheme disguised as an “investment club”.
  • Obtained partial acquittal of investment advisor on charges of investor fraud and wire fraud in lengthy jury trial in connection with allegations of a conspiracy to defraud TARP.
  • Secured a deferred prosecution agreement for one of the nation’s most prominent plaintiffs’ securities class action law firms in connection with seven years-long grand jury investigation related to approximately $11.3 million in alleged kickbacks to lead plaintiffs.
  • Achieved global resolution of criminal charges and private lawsuits against the former CEO of United Way for the National Capital Region accused of embezzling approximately $500,000.
  • Negotiated favorable plea agreement, SEC settlement, and conclusion of Congressional inquiry into key defendant in Enron investigation.
  • Persuaded SEC to close investigation of trader accused of using power market swaps to manipulate corporate earnings without any negative action against trader.
  • Supervised internal investigation of major university and concluded that whistleblower’s allegations of fraud and discrimination had no basis, while making recommendations for stronger internal controls.
  • Represented defendant in Enron investigation and supervised co-operation with government authorities to obtain substantial reduction of criminal sentence.

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