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GenAI Considerations for CFTC Registrants

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Morrison Foerster partners Rhys Bortignon, Stephanie Sharron, and Marijn Storm will lead the Futures Industry Association (FIA)...

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<p>Morrison Foerster partners Rhys Bortignon, Stephanie Sharron, and Marijn Storm will lead the Futures Industry Association (FIA) L&C Division webinar “GenAI Considerations for CFTC Registrants” on November 13, 2025. The webinar will explore the evolving regulatory landscape around artificial intelligence (AI), with an emphasis on generative AI. Critical legal considerations surrounding generative AI from both U.S. and EU perspectives will be examined. Topics include cybersecurity and technological risks, legal and compliance considerations, and what firms should anticipate as regulators adapt to rapid technological change.</p><hr>

<p>Futures Industry Association (FIA) L&C Division Webinar</p>

<p>GenAI Considerations for CFTC Registrants</p>

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<p>Rhys Bortignon is a partner in Morrison Foerster’s Capital Markets practice, based in New York. Rhys’ practice focuses on derivatives and structured products. He is a member of the firm’s Derivatives, Commodities + Structured Products practice group and Co-Head of its Securities + Derivatives Regulatory Solutions team.</p><p>With a focus on practical and commercial solutions, Rhys provides counsel to a diverse range of U.S. and international clients, from both the buy side and sell side, including corporates, investment banks, commercial banks, private equity, funds, investment managers, and sovereigns. Rhys offers strategic guidance to his clients from both a transactional and a regulatory perspective and navigates complex cross-border issues with proficiency, providing pragmatic advice to clients operating globally.</p><p>Rhys’ experience spans the spectrum of derivative transactions across asset classes, including rates, foreign exchange, credit, equity, digital assets, and commodities. He also frequently advises on margin loans, repo and securities lending transactions, the hedging components of project and corporate financings, as well as various structured products. </p><p>Rhys is well-versed in U.S. derivatives legal and regulatory matters under the Dodd-Frank Act, the Commodity Exchange Act, and the Securities Exchange Act as well as related CFTC, SEC, and prudential regulation, including the regulation of security-based swaps, swaps, futures and options as well as security-based swap dealers, futures commission merchants, introducing brokers, swap dealers, commodity pool operators, commodity trading advisors, and exchanges and clearing organizations. </p><p>Rhys advises on leading-edge issues in the derivatives space, such as AI, digital assets, distributed ledger technologies (including DeFi), energy transition matters, and sustainability-linked transactions. He frequently authors thought leadership pieces on current and proposed derivatives regulations in the United States.</p><p>Rhys sits on the Board of Directors of the LGBT Bar Association of New York, a voluntary professional organization dedicated to ensuring full equality for members of the LGBTQ+ community, promoting the advancement of LGBTQ+ legal professionals, and serving the larger community through various pro bono initiatives.</p><p>Prior to joining the firm, Rhys was counsel at another international law firm in New York. He also gained experience as an associate at leading law firms in London and Sydney. </p><p>Rhys is admitted to practice law in New York, England & Wales, and New South Wales, Australia.</p><h4>Representative Experience</h4><h5>Securitizations</h5><ul><li>Advised a global vehicle rental and leasing company with respect to its derivatives transactional and regulatory matters, including in connection with its international securitization platform and related financing activities</li></ul><h5>Equity Derivatives</h5><ul><li>Represented a leading geothermal company engaged in recovered energy generation in connection with its Rule 144A private offering of green convertible senior notes and the negotiation and execution of the associated capped call transactions with various dealer counterparties</li><li>Represented a data security and analytics pioneer in connection with its private Rule 144A offering of convertible senior notes, and the negotiation and execution of the associated capped call transactions with various dealer counterparties</li><li>Represented the initial purchasers and the capped call transaction counterparties in a digital sports betting and gaming platform’s offering of convertible senior notes, including the negotiation and execution of the associated capped call transactions</li><li>Represented a major South American mobile telecoms operator on its derivatives trading documentation in connection with its high-yield bond tap issuance</li><li>Represented the sole bookrunner in connection with the offering of a leading player in the global snack arena’s guaranteed zero-coupon exchangeable bonds and associated derivatives elements</li></ul><h5>Lending + Finance</h5><ul><li>Represented an international specialty finance company in connection with its global funding structure, which included: a notes offering; a consent solicitation of the holders of multiple preexisting issuances of notes; an amended multi-currency revolving credit facility; and the amendment and restatement of the company’s private placement notes purchase agreement</li><li>Represented a portfolio company of a Canadian asset management firm in connection with its entrance into a warehouse facility intended to finance a portfolio of consumer home rental contracts</li></ul><h5>Business Restructuring + Insolvency</h5><ul><li>Represented an operator of power infrastructure in the United States and its applicable debtor subsidiaries in connection with the consummation of the strategic transactions contemplated by the company’s chapter 11 plan of reorganization and provided assistance with the completion of its restructuring. The plan of reorganization entailed, among other components: the infusion of new equity capital pursuant to a common equity rights offering; a revolving credit facility; a Term Loan B credit facility; a Term Loan C credit facility; and a bilateral line of credit, as well as full repayment of the company's formerly existing first-lien funded debt and the consensual equitization of all of the company’s formerly existing unsecured notes. Representation included the drafting and negotiation of the foregoing debt financing transactions (including implementing intercreditor and first-lien security arrangements for derivative counterparties) and the renegotiation and implementation of commodity derivative documentation with several counterparties.</li></ul><h5>Project Finance</h5><p>Advised on the derivatives transactional and regulatory aspects of several high-profile project financing matters, including drafting and negotiation derivatives documentation, structuring hedging trades, and advising on intercreditor and other related matters:</p><ul><li>Represented a group of 13 commercial banks in connection with a non-recourse senior secured financing of the redevelopment of multiple terminals of a major global airport in the United States</li><li>Represented a group of international commercial banks in connection with a non-recourse financing of a wind project in Brazil</li><li>Represented a group of international banks as lenders and issuing banks in connection with the non-recourse first- and second-lien project financings of a wind farm and a solar power plant in Chile</li><li>Represented a leading private equity firm specializing in the energy industry in connection with a senior secured facility to finance the development, operation and maintenance of certain assets in the United States</li></ul><h5>M&A</h5><ul><li>Represented a leading private equity firm specializing in the energy industry in its sale of one of the premier independent utility-scale energy storage and renewable energy platforms in the United States to a French multinational utility company</li></ul>

Rhys Bortignon

Co-Head of Securities + Derivatives Regulatory Solutions

<p>Stephanie is a trusted advisor to companies with respect to technology and life sciences transactions, related IP counseling, and responsible tech and AI governance practices.</p><p>Stephanie represents both private and public companies, from emerging growth through the Fortune 50. For over 25 years, her practice has focused on helping companies that leverage data through technology.</p><p>Stephanie serves on the Responsible AI Venture Council, part of the recently launched Lucas Institute for Venture Ethics at Santa Clara University’s Markkula Center for Applied Ethics and currently serves as an advisor to certain research projects of the Institute. Stephanie is also a member of the firm’s global Sustainability + Corporate Responsibility and FinTech steering committees.</p><p>In addition to publishing on a variety of legal topics related to AI, since 2016, Stephanie has taught as a guest lecturer on data licensing and other IP-related topics in Cornell Law School’s Technology and Entrepreneurship LLM program at CornellTech and has served as a guest lecturer at Cornell Law School. </p>

Stephanie Lynn Sharron

Partner

<p>Marijn Storm specializes on the intersection of law and technology, with a focus on cutting-edge technologies, such as (generative) artificial intelligence (AI) and large language models, ethical tech, and biometrics. Based in Morrison Foerster’s Amsterdam office, he advises global companies and organizations on a wide range of their most complex and pressing privacy and data security challenges.</p><p>Marijn’s deep experience in both law and technology enables him to navigate the rapidly evolving landscape of privacy, data security, and technological innovation. Bridging the gap between legal requirements and technological advancements, Marijn advises and educates in-house legal teams on how to effectively manage and oversee technical applications such as AI and, specifically, generative AI. In addition, Marijn trains technical teams on implementing technical solutions in a privacy-by-design fashion, enabling compliance with AI and data protection laws around the world.</p><p>Marijn also represents clients in class action and other litigation. For example, he has defended both digital advertising and public health clients against claims of alleged GDPR violations. In addition, he counsels clients on investigating and responding to major cybersecurity and ransomware incidents, including notification and related obligations. Marijn has also assisted a number of companies in obtaining regulatory approval for their Binding Corporate Rules, in both the EU and the UK.</p><p>A recognized thought leader, Marijn regularly speaks at international data protection conferences (including IAPP) on topics such as the future of behavioral biometrics, the ethical application of AI, and developments in EU class actions. Marijn frequently publishes articles and client alerts on a variety of evolving topics, such as the EU AI Act and the NIST AI Risk Management Framework. Since 2019, he has been a guest lecturer at the Tilburg Institute for Law, Technology, and Society, where he teaches Algorithmic Accountability within the biannual course on AI & Law.</p><p>Marijn is a Dutch-qualified lawyer and is fluent in Dutch and English.</p>

GenAI Considerations for CFTC Registrants

13 Nov 2025 9:00 AM - 10:00 AM EST