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Deborah North


New York

North Deborah
Deborah North


New York

Deborah advises on a broad range of derivatives and structured finance transactions, with a focus on OTC derivatives and structured synthetic products as well as the cross border security arrangements that they often entail. As such, she has recently advised on a range of products including several credit linked notes, structured repos, contingent credit default swaps and equity derivatives transactions. She also advises on insurance-linked products. Given her transactional and regulatory derivatives experience she has been called upon by several clients in the legal/tech and fintech space to create documentation frameworks and multi-jurisdictional regulatory analysis for their start-up offerings.

Deborah is recognized as an expert on the clearing of OTC derivatives. Her work in this area includes advising on the standard documentation for the clearing of OTC derivatives, advising on the rulebooks for in excess of 20 existing and prospective clearing houses and engaging with the CFTC, the Federal Reserve Board and the SEC on clearing related matters. Her clients include financial institutions, industry associations and clearing houses such as CME Group. Notably Deborah advised ISDA and market participants on a number of clearing-related US law opinions that address some of the significant capital related issues in this space.

Deborah has developed an extensive derivatives regulatory practice. She has advised a number of financial institutions on their registration as swap dealers, including on all aspects of compliance materials, documentation and interaction with the CFTC, NFA and, where applicable, their European home regulators. She regularly advises clients, including industry associations such as SIFMA, SIFMA AMG, Investment Company Institute (ICI) and most recently in the context of the rules regarding swaps execution facilities and industry trade, ISDA on their comment letters and responses to regulatory proposals.

More recently she has focused on advising on the regulations for margin for uncleared swaps and the impact of bank resolution and recovery tools on derivatives transactions, advising primarily financial institutions as well as industry associations. In the context of uncleared margin, in addition to advising individual clients she was instrumental to the U.S. focused documentation efforts for Phase 1 dealers. She is also in the process of helping US-based clients and industry associations address the impact of European regulation and Brexit. Deborah advised on the template bilateral documentation published by ISDA for the US QFC Stay rules and is advising US and Non-US GSIBs on their implementation efforts. Deborah is also currently advising market participants on the potential effect of LIBOR discontinuation.

Deborah is regularly asked to speak and write on her areas of expertise. She recently contributed the U.S. chapter to a book on global derivatives regulation and was invited to speak on those issues by ISDA, SIFMA AMG, ISDA and DTCC.

Deborah is ranked in Band 2 in Chambers USA, 2018 and as a leading individual in Chambers USA, 2017.  She is praised by clients in Chambers for her "excellent customer service and strong technical knowledge of derivatives and margin rules" and for her “very detailed review and ability to look at the practicalities of the problem and see it for what it really was.”

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Capital Markets




New York

Allen & Overy LLP
1221 Avenue of the Americas
New York
NY 10020

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Admitted: Bar of the State of New York, 2000

Admitted: Solicitor of England and Wales, 2000


LLB, Law (Hons) King's College, London, 1996

Diploma in Legal Practice (Distinction), College of Law, 1997

Published work

  • 'Long Live the Difference?' International Financial Law Review, March 2011, by Deborah North with James Druce
  • 'CDS Clearing: the New World Order', Derivatives Week, April 5, 2010, by Deborah North, Damian Carolan, Yusef Battiwala and Irina Molostova
  • 'Regulatory Consistency In the US and Europe', Derivatives Week, October 18, 2010 by Deborah North, Damian Carolan, David Lucking and Emma Dwyer
  • 'Interest Shortfalls in CDS on CDO Documents', Derivatives Week, November 12, 2007 by Deborah North and Shruti Ajitsaria
  • Reporting The Future: The CFTC’s Final Rule On Real-Time, 01/18/2012
  • Reporting Swap Data: The CFTC's Final Rule On Swap Data Recordkeeping And Reporting Requirements, 01/23/2012
  • CFTC Adopts Pay-to-Play Rule for Swap Dealers, 02/27/2012
  • "To Conform or Not to Conform": The Federal Reserve releases guidance on obligations of banking entities under the Volcker Rule during the conformance period, 04/26/2012
  • New Report on International Standards for OTC Derivatives Market Intermediaries - Is US-style Derivatives Regulation Coming Your Way?, 06/20/2012
  • The "Intergalactic Commerce Clause"?: The CFTC's Proposed Cross Border Guidance Reaches Far and Wide, 07/02/2012
  • The "Intergalactic Commerce Clause"?: The CFTC's Proposed Cross Border Guidance Reaches Far and Wide, 07/03/2012
  • Commodity Pool Issues Raised by The Dodd-Frank Act, 10/02/2012
  • Securitizations, Covered Bonds and Commodity Pool Regulations – The CFTC Interpretative Letter, 10/12/2012
  • FX Swaps and Forwards – Time limited no-action relief, 10/15/2012
  • "U.S. Person" Definition Time-Limited No-Action Relief – CFTC No-Action Letter 12-22, 10/15/2012
  • Staff No-Action Positions: Registration relief for certain persons, 10/15/2012
  • ECP Status w/r/t Guarantee Arrangements, "Anticipatory ECPs" and Amounts Invested on a Discretionary Basis, 10/15/2012
  • CFTC Final Rules Updates, 10/18/2012
  • Internal Business Conduct Rule Recordkeeping Requirements—Time-Limited No-Action Relief: CFTC No-Action Letter 12-29, 11/05/2012
  • Special FX - The Treasury's Limited FX Exemption, 11/20/2012
  • "Creeping Subsidiarization": The upcoming Federal Reserve proposal on regulation of foreign banking organizations, 11/30/2012
  • Funds of Funds Get Some Temporary CPO Relief, 12/03/2012
  • CFTC No-Action Relief from certain Swap Dealer registration requirements, 12/21/2012. 
  • Interim Final Rules on Business Conduct and Documentation Requirements for Swap Dealers and Major Swap Participants, 12/21/2012
  • Temporary Course Correction: CFTC Issues Final Cross-Border Exemptive Order and Further Proposed Guidance, 12/24/2012
  • Federal Agencies Adopt Final Volcker Rule and Extend Conformance Period, 12/13/2013
  • CFTC Issues Substituted Compliance Determinations for Six Jurisdictions, 12/20/2013
  • Congress largely scraps the Dodd-Frank push-out rule, 12/23/2014
  • Take Two: CFTC revisits cost benefit analysis of cross border aspects of Dodd Frank swaps rules, 03/18/2015
  • EMIR margin requirements for non-centrally cleared derivatives: EU edges closer to final rules with second consultation on draft RTS, 06/24/2015
  • Puerto Rico: "Always the Hurricanes Blowing… And the Money wing…", 07/01/2015
  • Harmony or Cacophony: The CFTC's Proposal on the Cross-Border Approach to Margin Requirements for Uncleared Swaps, 07/07/2015
  • ASX Cleared for Landing in the U.S., 08/21/2015
  • SEC Adopts Rules And Forms Establishing A Registration Process For Security-Based Swap Entities; Compliance Date Still Some Time Off, 08/27/2015
  • "LOSS" IN TRANSLATION: U.S. Bankruptcy Court issues ruling on key provision of the 1992 ISDA Master Agreement, 11/13/2015
  • Benchmark regulation shifts up a gear, 03/08/2016
  • Summary of Key Changes in the CFTC Final Rule on Cross Border Application of Margin Requirements for Non-Cleared Swaps, 05/25/2016
  • EU Benchmark Regulation – fleshing out key concepts, 06/16/2016

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