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Jonathan Flynn

Senior Counsel

Washington, D.C.

Flynn Jonathan
Jonathan Flynn

Senior Counsel

Washington, D.C.

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.

News & insights

News: 13 DECEMBER 2019

Allen & Overy bolsters team with the appointment of arbitration Partner Anna Masser in Frankfurt

Allen & Overy continues to expand its German Dispute Resolution practice with the appointment of Anna Masser, who is due to join the firm's Frankfurt office as a partner on 1 February 2020. A respected international arbitration expert, she will head up Allen & Overy’s German Arbitration practice and will focus on international commercial arbitration in particular. She joins from Jones Day, where she was made partner at the beginning of the year.

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Publications: 19 AUGUST 2019

Allen & Overy’s Fintech group leads as Contributing Editor to the first edition of Global Legal Insights Guide to: Fintech 2019

As part of our role as Contributing Editor, members of A&O’s Fintech group in the U.S. authored the preface of the publication, as well as one general chapter. Our colleagues in Germany, Indonesia and the Czech Republic contributed four country chapters. 

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Digital panels

Publications: 28 JUNE 2019

New CME Guidance Puts Trading in the Pre-Open Period in the Spotlight

On April 11, 2019, CME, CBOT, NYMEX, and COMEX collectively published potentially significant revisions to the guidance on the CME Globex pre-open process.

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Publications: 19 DECEMBER 2017

Crypto-Derivatives: New Products, for New Participants in the Futures and Swaps Markets

​On December 1, 2017, the Chicago Mercantile Exchange ("CME"), the CBOE Futures Exchange ("CBOE"), and Cantor Exchange ("Cantor") self-certified three new contracts for bitcoin derivatives. Bitcoin futures started trading on CBOE on December 10. CME started trading of its bitcoin futures contract on December 18. Cantor’s exchange-traded bitcoin swaps are expected to begin trading before the end of 2017.

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Washington, D.C.

Allen & Overy LLP
1101 New York Avenue, NW
Washington, D.C.

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District of Columbia



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

B.A., Dartmouth College

Published work

“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