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Jonathan Flynn

Senior Counsel


Flynn Jonathan
Jonathan Flynn

Senior Counsel


Jonathan Flynn focuses his practice on commodities, securities, derivatives and related regulatory and litigation matters. He represents a wide range of participants in the physical commodity and financial markets, including investment banks, major commodity merchants and trading houses, hedge funds and other asset managers, market intermediaries, and industry trade associations, on a broad range of regulatory issues involving the Commodity Futures Trading Commission (CFTC), the National Futures Association (NFA), the Securities and Exchange Commission (SEC), and the Federal Trade Commission (FTC). Jon also represents companies and individuals in government investigations by the government regulators and the U.S. Department of Justice related to manipulation, fraud, price reporting and commodity indexes, supervisory controls, position limits, and other prohibited trade practices.

Jon has extensive experience with administrative rulemaking and the legislative process. He lobbied successfully on behalf of industry trade associations and individual market participants for amendments to the Dodd-Frank Act prior to enactment. He continues to represent clients in agency rulemakings, and counsels clients regularly on compliance and implementation issues related to new CFTC and SEC regulations.

Prior to returning to private practice, in 2012 and 2013, Jon served as a policy advisor on derivatives at the SEC. During this time, he represented SEC staff in various international working groups, including IOSCO’s Task Force on OTC Derivatives and the Financial Stability Board’s OTC Derivatives Working Group, and coordinated with other U.S. financial regulators, including the CFTC, Treasury, Federal Reserve Board, and Federal Reserve Bank of New York on policy issues related to implementation of the Dodd-Frank Wall Street Reform and Consumer Protection Act. Jon also worked extensively on the SEC’s proposed rule on cross-border security-based swap activities and international efforts to develop a harmonized approach to the cross-border regulation of derivatives.

Related articles

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Publications: 14 June 2022

Lummis-Gillibrand Responsible Financial Innovation Act proposes comprehensive regulatory framework for digital assets in the United States

On June 7, 2022, Senator Kirsten Gillibrand (D-NY) and Senator Cynthia Lummis (R-WY) introduced the Responsible Financial Innovation Act (RFIA), a highly anticipated legislative proposal that, if…

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Publications: 06 June 2022

Voluntary carbon markets: Analysis of regulatory oversight in the U.S.

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Publications: 26 October 2020

U.S. Commodity Futures Trading Commission issues final position limits rule

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Publications: 27 August 2020

Allen & Overy’s Fintech group returns as contributing editor to the second edition of Global Legal Insights Guide to: Fintech 2020

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One Beacon Street
MA 02108

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District of Columbia



J.D., cum laude, Georgetown University Law Center

B.A., Dartmouth College

Published work

  •  "Crypto-tunities: Transaction strategies in the challenging crypto markets", Allen & Overy update, July 13, 2022
  • “Inside the New Forex Market Code of Conduct,” Law360 (June 9, 2016), with Anthony Mansfield, Gregory Mocek, and Jorge Pesok
  • “Regulators are Widening the Spoofing Net,” Law360 (May 26, 2016), with Anthony Mansfield, Paul Pantano, and Gregory Mocek
  • “Compliance Departments Must Continue to Evolve as Regulators Refine Their Approach to Spoofing,” The National Law Review (May 5, 2016), with Anthony Mansfield, Paul Pantano, and Gregory Mocek
  • “Spoofing – A New Amorphous Crime With Domestic and International Implications for Traders,” Commodities Now Magazine (Feb. 2016), with Gregory Mocek
  • “Building the House Before the Foundation,” Energy Metro Desk (Feb. 21, 2011), with Gregory Mocek and Benjamin Chesson