Profile

Daren F. Stanaway is Associate General Counsel - Investigations & Enforcement at Interactive Brokers in Washington, D.C., where she oversees and manages the firm's responses to inquiries and investigations by federal and state regulators, exchanges, and self-regulatory organizations (SROs), including the Financial Industry Regulatory Authority (FINRA), the Securities and Exchange Commission (SEC), and the Commodity Futures Trading Commission (CFTC).  She was previously of counsel in the Litigation practice at Paul Hastings and based in the firm’s Washington, D.C. office, where her practice focused on white collar litigation and defense and government investigations and enforcement initiatives.

In private practice, Ms. Stanaway represented prominent corporations, financial institutions, individuals, and other securities and commodities market participants in federal and state court litigation and administrative actions, and in investigations by the Department of Justice (DOJ), the SEC, the Federal Energy Regulatory Commission (FERC), the CFTC, the Chicago Mercantile Exchange (CME), the Intercontinental Exchange (ICE), and congressional committees. Her practice included pretrial and appellate briefing in numerous federal district and appellate courts in the white collar, securities, commodities, derivatives, and environmental fields. Ms. Stanaway currently serves as the Vice Chair of the Jurisdiction Working Group of the Innovative Digitized Products and Processes Subcommittee (IDPPS) of the ABA Derivatives and Futures Law Committee.

Ms. Stanaway received her J.D. from Harvard Law School in 2010, where she received the Dean’s Scholar Prize and served as Senior Editor of the Harvard Journal of Law and Public Policy. She graduated with a B.A., magna cum laude, Phi Beta Kappa, from Harvard College in 2007. Ms. Stanaway is admitted to practice law in Massachusetts and the District of Columbia, and before the United States Supreme Court.

Recent Representations

• Represented employee at a large financial institution in connection with DOJ and CFTC investigations of alleged spoofing and disruptive trading practices.
• Represented commodity producer in connection with CFTC and CME investigations regarding alleged benchmark manipulation.
• Represented trader at a large energy firm in connection with FERC and U.S. Attorney’s Office investigations of the default and failure of a financial trading firm.
• Advised several companies in the cryptocurrency and FinTech space regarding CFTC and SEC regulation and enforcement activity.
• Represented medical billing service provider in private dispute concerning outstanding receivables.
• Represented trader at an energy firm in connection with ICE investigation of alleged spoofing and other disruptive trading practices.
• Represented global financial institution in industry-wide investigations by agencies in several countries and related class action litigation regarding alleged manipulation of the Yen LIBOR, Euroyen TIBOR, and U.S. Dollar LIBOR benchmarks.
• Represented several employees of large multinational financial institutions in SEC and DOJ Foreign Corrupt Practices Act (FCPA) investigations concerning alleged bribery and foreign hiring practices.
• Represented employee of large medical device manufacturer in DOJ investigation concerning distribution of allegedly misbranded medical devices.
• Successfully defended two former Barclays traders in FERC enforcement action alleging market manipulation in western electricity markets, including procuring the dismissal of one trader from the case at the pleading stage. The case marked the first judicial review of FERC’s new antifraud authority.
• Represented major global financial institution before the DOJ in connection with the use by U.S. clients of offshore accounts to avoid taxes.
• Won a complete dismissal, with prejudice, of a complex international trade secrets action against a large Korean corporation in federal district court. The dismissed claims involved alleged violations of the Racketeer Influenced and Corrupt Organizations Act (RICO) and the Lanham Act, as well as alleged trade secret theft under New York and California law.
• Represented Money Services Business (MSB) in government Bank Secrecy Act (BSA) and anti-money laundering (AML) investigation.
• Successfully defended Thomas Lund, the former Executive Vice President and head of Fannie Mae’s Single Family business, against securities fraud charges filed by the SEC in the Southern District of New York. After three years of litigation, the SEC discontinued its case against Mr. Lund without obtaining any of the relief sought in its Complaint.
• Represented a former corporate officer in connection with an SEC investigation concerning accounting misstatements and a corporate restatement.
• Represented a major financial institution in a Sixth Circuit appeal arising out of a securities fraud and Ponzi scheme executed by another financial institution and its principals.
• Represented a nonoperating leaseholder in multidistrict litigation stemming from the Deepwater Horizon oil spill in the Gulf of Mexico.

SPEAKING ENGAGEMENTS AND PUBLICATIONS

Speaking Engagements

·        Panelist, Retail Trading, Futures Industry Association Law & Compliance Division Conference (April 25, 2025)

·        Panelist, Market Structure Developments, ABA Derivatives & Futures Law Committee Winter Meeting (January 31, 2025)

·        Guest Speaker, The Real Lawyer Podcast, Sophia Media LLC (December 30, 2024-January 3, 2025)

·        Panelist, Enforcement Developments, ABA Derivatives & Futures Law Committee Winter Meeting (February 2, 2023)

·        Panelist, Ethics in Derivatives and Futures Law, Futures Industry Association Law & Compliance Division Conference (April 29, 2022)

·        Panelist, Developments in Retail Markets, ABA Derivatives & Futures Law Committee Winter Meeting (January 27, 2022)

·        Panelist, Enforcement Developments, ABA Derivatives & Futures Law Committee Winter Meeting (January 28, 2021)

·        Panelist, CFTC Cryptocurrency Regulation: What’s Next?, Webinar (November 17, 2020)

·        Panelist, Recent CFTC Enforcement Developments, District of Columbia Bar Webcast (October 27, 2020)

·        Panelist, Navigating COVID-19 Relief Fraud, Webinar (October 1, 2020)

·        Panelist, The Future of CFTC Enforcement & Regulation: What Lies Ahead in 2018, Webinar (April 30, 2018)

Publications

·        Contributing Author, “Digital and Digitized Assets: Federal and State Jurisdictional Issues,” American Bar Association Derivatives and Futures Law Committee Innovative Digital Products and Processes Subcommittee Jurisdiction Working Group (September 2025)

·        Author, “Reforming Securities Fraud Sentencing: An Alternative Proposal to a Loss-Based Approach,” ABA White Collar Crime Committee Newsletter (Winter/Spring 2021)

·        Author, “DOJ Publishes Framework Highlighting Priorities in Cryptocurrency Enforcement,” ABA Derivatives & Futures Law Committee Winter Meeting (January 2021)

·        Author, “Expanded Regulatory Scrutiny of Derivatives Anti-Money Laundering Compliance,” ABA Derivatives & Futures Law Committee Winter Meeting (January 2021)

·        Contributing Author and Editor, “Digital and Digitized Assets: Federal and State Jurisdictional Issues,” American Bar Association Derivatives and Futures Law Committee Innovative Digital Products and Processes Subcommittee Jurisdiction Working Group (December 2020)

·        Author, “Regulators Continue to Emphasize Anti-Money Laundering Compliance,” Paul Hastings Client Alert (October 16, 2020)

·        Author, “ARRC Updates Bilateral Loan Recommended Hardwired Fallback Language and Syndicated Loan Conventions,” Paul Hastings Client Alert (October 2, 2020)

·        Author, “CFTC Continues Pursuit of Misuse of Material Nonpublic Information Following Settlement with NYMEX,” Paul Hastings Client Alert (September 28, 2020)

·        Author, “ARRC Encourages Adherence to ISDA IBOR Fallback Protocol,” Paul Hastings Client Alert (September 18, 2020)

·        Author, “Beware of COVID Relief Fraud,” Paul Hastings Client Alert (September 17, 2020)

·        Author, “ARRC Releases SOFR ‘In Arrears’ Conventions for Syndicated Business Loans,” Paul Hastings Client Alert (August 28, 2020)

·        Author, “ARRC Publishes the SOFR Starter Kit: An Up-to-Date Summary of the Transition Away from USD LIBOR,” Paul Hastings Client Alert (August 26, 2020)

·        Author, “Bloomberg Begins Publishing Fallback Rates for Certain Key IBORs,” Paul Hastings Client Alert (July 24, 2020)

·        Author, “ARRC Announces Further Details of Recommended Spread Adjustments for Cash Products,” Paul Hastings Client Alert (July 7, 2020)

·        Author, “FCA to be Granted Enhanced Powers to Ensure Orderly Wind-down of Libor Contracts,” Paul Hastings Client Alert (July 1, 2020)

·        Author, “ARRC Recommends Best Practices for Completing LIBOR Transition,” Paul Hastings Client Alert (June 5, 2020)

·        Author, “In Search of Restraint: Vorley Wire Fraud Ruling Injects Uncertainty into the Commodities Trading Laws,” Futures & Derivatives Law Report, Vol. 40, Issue 5, at 1 (May 2020)

·        Author, “ARRC Releases Supplemental Consultation on LIBOR-to-SOFR Spread Adjustment Methodology,” Paul Hastings Client Alert (May 21, 2020)

·        Author, “Prosecutorial Deference Versus Due Process: The Federal Power Act and Perpetual Statutes of Limitations,” Energy Law Journal, Vol. 41, No. 1, at 71-91 (May 2020)

·        Author, “Déjà-vu All Over Again: Government Enforcement in Response to Economic Crises,” Paul Hastings Client Alert (May 6, 2020)

·        Author, “ARRC Proposes New York State Legislation to Facilitate LIBOR-to-SOFR Transition,” Paul Hastings Client Alert (April 27, 2020)

·        Author, “ISDA Announces Preliminary Results of LIBOR Pre-cessation Fallbacks Consultation,” Paul Hastings Client Alert (April 24, 2020)

·        Author, “ARRC Announces Recommended Spread Adjustment Methodology for Cash Products,” Paul Hastings Client Alert (April 16, 2020)

·        Author, “SEC and CFTC Issue Additional Relief to Address Growing Coronavirus Concerns,” Paul Hastings Coronavirus Task Force (April 3, 2020)

·        Author, “Navigating Share Repurchases in Volatile Markets,” Paul Hastings Client Alert (March 17, 2020)

·        Author, “SEC Facilitates Cboe Shift to Electronic Trading,” Paul Hastings Coronavirus Task Force (March 15, 2020)

·        Author, “SEC Releases Additional Guidance to Promote Virtual Annual Meetings and Grants Additional Relief to Investment Advisers and Investment Funds,” Paul Hastings Coronavirus Task Force (March 13, 2020)

·        Author, “Community Spread, Social Distance, and the Economic Gap: More Dramatic Governmental and Institutional Responses to the Coronavirus,” Paul Hastings Coronavirus Task Force (March 13, 2020)

·        Author, “Interpreting the Federal Government’s Next Steps Regarding the Coronavirus,” Paul Hastings Coronavirus Task Force (March 12, 2020)

·        Author, “New York Fed Begins Publication of SOFR Averages and a SOFR Index,” Paul Hastings Client Alert (March 9, 2020)

·        Author, “PH COVID-19 Client Alert Series: Regulatory and Corporate Governance Implications,” Paul Hastings Client Alert (March 4, 2020)

·        Author, “CFTC Approves New Proposed Position Limits Rule,” Paul Hastings Client Alert (February 24, 2020)

·        Author, “ARRC Releases Vendor Survey and Buy-Side Checklist for Transition to SOFR,” Paul Hastings Client Alert (February 6, 2020)

·        Author, “Vorley Wire Fraud Ruling Inconsistent with Precedent and the Commodity Exchange Act,” ABA Derivatives & Futures Law Committee Winter Meeting (January 2020)

·        Author, “CFTC Chairman Pledges Support for LIBOR-to-SOFR Transition,” Paul Hastings Client Alert (December 13, 2019)

·        Author, “SEC Case Opens Door for Investor Whistleblowers,” Law360 (December 3, 2019)

·        Author, “The SEC Clears the Path for Investors as Potential Whistleblowers: Greater Scrutiny May Be on the Horizon During Regulatory Examinations,” Paul Hastings Client Alert (November 21, 2019)

·        Author, “ARRC's Fifth Set of Recommended Fallback Language: Residential Adjustable-Rate Mortgages,” Paul Hastings Client Alert (November 18, 2019)

·        Author, “CFTC and SEC Charge Foreign Trading Platform Transacting in Security-Based Swaps and Commodity Futures with U.S. Invertors,” Paul Hastings Client Alert (November 8, 2019)

·        Author, “ABA Business Law Section Comments on IOSCO Cryptocurrency Guidance,” ABA Business Law Today (November 2019)

·        Author, “CFTC to Commence New Examination Program Targeting Swap Dealers and CPOs,” Paul Hastings Client Alert (November 1, 2019)

·        Author, “Proposed Amendments to U.S. Prudential Regulators’ Margin Rules for Non-Cleared Swaps,” Paul Hastings Client Alert (October 25, 2019)

·        Author, “SEC Charges Bevy of Foreign Traders in Alleged Spoofing Ring,” Paul Hastings Client Alert (October 24, 2019)

·        Author, “Reporting for Duty: CFTC Clamps Down on Swap Reporting and Risk Management,” Paul Hastings Client Alert (October 11, 2019)

·        Author, “ARRC Releases Practical Implementation Checklist for SOFR Adoption,” Paul Hastings Client Alert (October 1, 2019)

·        Author, “Whistleblower Initiatives Clarify CFTC Enforcement Priorities,” Law360 (September 26, 2019)

·        Author, “CFTC Paying for a Company’s Dirty Laundry: New Whistleblower Initiatives and Rewards Suggest Increased Enforcement in the Virtual Currency, Foreign Corrupt Practices, Insider Trading, and BSA Spaces,” Paul Hastings Client Alert (September 24, 2019)

·        Author, “SEC Adopts Capital, Margin, and Collateral Segregation Requirements for Security-Based Swaps,” Paul Hastings Client Alert (August 8, 2019)

·        Author, “Landmark ABP Deal Achieves First Amendment of LIBOR Legacy Bond to New Alternative Rate,” Paul Hastings Client Alert (June 17, 2019)

·        Author, “SEC Proposes Action Regarding Cross-Border Application of Certain Security-Based Swap Rules,” Paul Hastings Client Alert (June 11, 2019)

·        Author, “CFTC Reaffirms Focus on Foreign Corrupt Practices,” Paul Hastings Client Alert (June 5, 2019)

·        Author, “ARRC Releases Recommended Fallback Language for Floating Rate Notes and Syndicated Loans,” Paul Hastings Client Alert (May 23, 2019)

·        Author, “The Commodity Futures Trading Commission’s Foray into Foreign Bribery Enforcement: What Does It Mean?,” Futures Industry Association (FIA) Law & Compliance Division Conference (May 2019)

·        Author, “ARRC Releases White Paper Regarding SOFR – The New U.S. Dollar LIBOR Alternative,” Paul Hastings Client Alert (April 29, 2019)

·        Author, “ABA Releases White Paper Regarding Cryptocurrencies and Digital Assets,” Paul Hastings Client Alert (March 19, 2019)

·        Author, “A New Enforcement Agency Joins the World of International Corruption Enforcement: CFTC Announces New Initiative Covering Companies Involved in Foreign Corrupt Practices,” Paul Hastings Client Alert (March 13, 2019)

·        Contributing Author, “Digital and Digitized Assets: Federal and State Jurisdictional Issues,” American Bar Association Derivatives and Futures Law Committee Innovative Digital Products and Processes Subcommittee Jurisdiction Working Group (March 2019)

·        Author, “Blockchain and Cryptocurrencies: A Cross-Border Conundrum,” ABA Derivatives & Futures Law Committee Winter Meeting (January 2019), published in the Journal of Investment Compliance, Vol. 20, No. 3, at 10-19 (2019) (2020 Literati Award winner)

·        Author, “DRW Decision Presents Significant Interpretation of CFTC Authority,” Paul Hastings Client Alert (December 10, 2018)

·        Author, “The Effects of the Supreme Court’s Lucia v. SEC Decision across Administrative Agencies,” Infrastructure, Vol. 57, No. 4, at 3 (Summer 2018)

·        Author, “Spoofing, Manipulation, and Scienter in the Context of Post-Dodd-Frank Litigation,” Futures Industry Association (FIA) Law & Compliance Division Conference (May 2018)

·        Author, “The Interplay Among Spoofing, Manipulation, and Scienter in the Wake of Dodd-Frank,” ABA Annual National Institute on White Collar Crime (March 2018)

·        Author, “The Extraterritorial Reach of the Commodity Exchange Act in the Wake of Morrison and Dodd-Frank,” Futures & Derivatives Law Report, Vol. 37, Issue 7, at 1 (July 2017)

​Former member of the Washington DC Chapter.