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
Congress’s push to reclassify certain event contracts reflects a jurisdictional judgment rather than a philosophical one. Lawmakers advancing the Prediction Markets Are Gambling Act appear concerned that CFTC oversight has enabled sports and casino-style contracts to be offered nationwide through a federal derivatives framework that was not designed to incorporate traditional gambling safeguards. By designating these contracts as gambling subject to state and tribal regulation, the bill…
The new CRS report provides an objective overview of how predictive market platforms look like casinos to some, derivatives exchanges to others, and catnip to regulators caught in the middle. Event contracts are federally regulated commodities products, yet their subject matter increasingly overlaps with sports betting and elections, areas traditionally policed by the states. The result is a regulatory Rorschach test: Are these markets sophisticated price‑discovery tools or simply…
Across the FAQs and staff letters, the Commission has carefully opened the door to crypto‑adjacent collateral while keeping one foot firmly on the brake. Tokenization does not create new eligible assets, payment stablecoins are tolerated only within tightly fenced uses, and crypto margin relief lives squarely in listed and cleared markets, however, not uncleared swaps.
For FCMs, the opportunity is real but conditional. Crypto collateral may improve liquidity and collateral mobility,…
Regulators are signaling that trades tied to real‑world outcomes may be popular, but they are not casual products. Where a market turns on a single decision, moment, or source of information, staff is openly questioning whether the structure can withstand abuse. For exchanges, that means sharper boundaries around what can be listed, tighter controls around how outcomes are determined, and more external coordination in sensitive areas like athletics—because novelty alone will not offset…