Senior Counsel
Stephan Ariyan is an energy and commodities lawyer based in Houston. He provides legal and regulatory advice to energy and commodity trading companies with operations around the globe.
With over 25 years of progressive experience in international markets, Stephan advises on matters before the FERC, CFTC, ICE, and CME futures exchanges. Additionally, he supports regulatory compliance with the SEC, FINCEN, OFAC, the FCPA, and Dodd-Frank regulations, as well as international frameworks including the UK and EU's EMIR, MiFID II, the UK Bribery Act, and other relevant laws impacting commodity trading markets.
Recent Articles & Comments
The CFTC’s request for comment on prediction markets is best read as an opportunity for market participants: the regulatory perimeter is being redrawn in real time. By openly questioning how existing exchange principles apply to event contracts—and where public‑interest concerns, retail access, and information asymmetries should set hard limits—the Commission is inviting industry input before those boundaries calcify into rules or enforcement positions. Firms operating or transacting in…
This No-Action letter offers significant benefits for energy companies navigating the complexities of swap dealer registration. By excluding certain energy commodity end-user swaps from the de minimis calculation, the relief expands hedging options, enabling more energy companies to participate as counterparties. This increased participation is expected to enhance market liquidity and drive down hedging costs, making risk management more accessible across the sector.
Importantly, the…