FacultyFaculty/Author Profile
K. Susan Grafton

K. Susan Grafton

Dechert LLP

Washington, DC, USA


Susan Grafton leads Dechert’s Broker-Dealer, Securities Trading and Markets practice and co-leads its FinTech practice. She is consistently ranked nationally by Chambers USA in the Broker-Dealer (Compliance) and Broker-Dealer (Enforcement) categories. Among other comments, clients note her “problem-solving orientation. I find her to be very practical and she can work with us on getting to a positive resolution. She always has her client's goals in mind.” (Chambers USA 2017). Market observers call her “an excellent regulatory attorney” and note that “Susan’s work as always been very impressive.” (Chambers USA 2018). They also note that she is “very well connected in the industry, and is able to get the SEC and FINRA to be more responsive” (Chambers USA 2016). Clients also describe her as “a go-to attorney…especially in Regulation M issues and distribution type questions, [where] she's very knowledgeable” (Chambers USA 2015).

Ms. Grafton counsels a wide range of broker-dealers, including alternative trading systems, on all aspects of their business, including registration and changes in control; sales practices, including proposed Regulation Best Interest; trading and execution issues, including compliance with best execution, trade and order reporting, and Regulation NMS and SHO requirements; and Regulation M and FINRA’s corporate finance rules. Her practice also includes representing investment avisers, including hedge fund managers, on a variety of issues, including broker-dealer status issues and solutions to avoiding broker-dealer registration, the use of expert networks, handling material non-public information, and compliance with Rule 105 of Regulation M. She advises buy-side and sell-side clients on soft dollar issues and intersection between Section 28(e) and MiFID II.

In addition, Ms. Grafton frequently represents clients before the SEC and FINRA in connection with regulatory examinations and enforcement investigations pertaining to a wide range of issues.

Ms. Grafton has a unique combination of regulatory, in-house and law firm experience. She began her career with the SEC’s Division of Trading and Markets, and subsequently served as a vice president and associate general counsel of Goldman Sachs & Co. where she advised on a variety of strategic, regulatory compliance and operational issues related to the firm’s institutional equities sales and trading businesses.

K. Susan Grafton is associated with the following items:
CHB Chapters  CHB Chapters K. Susan Grafton and Linda J. Muzere, Challenges for Private Fund Advisers in Establishing and Maintaining a Compliance Program (September 29, 2017) - Hedge Fund and Private Equity Enforcement & Regulatory Developments 2017, Friday, December 01, 2017
Constructing an Effective Compliance Program for Private Fund Advisers (November 22, 2017) - Private Fund Regulatory Developments and Compliance Challenges 2018, Thursday, February 01, 2018
FinCEN Warns That Virtual Currency Activities Are Subject to Anti-Money Laundering Obligations (April 2018) - FinTech 2018, Monday, August 13, 2018
Irish Government Releases Paper on Virtual Currencies and Blockchain Technology (April 2018) - FinTech 2018, Monday, August 13, 2018
The Securities Exchange Commission’s Section 21(a) Report on “The DAO”: Are Virtual Tokens or Currency Securities? (August 16, 2017) - FinTech 2018, Monday, August 13, 2018
OFAC Releases Guidance on Cryptocurrency (April 2018) - FinTech 2018, Monday, August 13, 2018
FCA Publishes Statement on Cryptocurrency Derivatives (May 2018) - FinTech 2018, Monday, August 13, 2018
Employers: Are You Ready for a Cyberwar? Attackers Using Ransomware Are Saying Show Me Your Bitcoin! (May 2017) - FinTech 2018, Monday, August 13, 2018
Bitcoin Futures Trading Commences; Implications for Funds and Registered CPOs and CTAs (December 2017) - FinTech 2018, Monday, August 13, 2018
Wyoming Passes Law Creating New Asset Class for Cryptocurrencies (March 2018) - FinTech 2018, Monday, August 13, 2018
House Financial Services Committee Holds Hearing to Discuss Cryptocurrencies, ICOs (March 2018) - FinTech 2018, Monday, August 13, 2018
The European Commission Action Plan for FinTech Includes Blockchain Priorities (March 2018) - FinTech 2018, Monday, August 13, 2018
NASAA Announces Results of “Operation Cryptosweep,” Praised by SEC Chairman (May 2018) - FinTech 2018, Monday, August 13, 2018
U.S. v. Coinbase: Virtual Currency Holders Not Outside the IRS’s Reach (December 2017) - FinTech 2018, Monday, August 13, 2018
SEC Staff Seeks Industry Engagement on Questions Regarding Development of Funds Holding Cryptocurrency-Related Products (January 2018) - FinTech 2018, Monday, August 13, 2018
Federal Court Ruling Recognizes CFTC Jurisdiction over Cryptocurrencies as Commodities (March 2018) - FinTech 2018, Monday, August 13, 2018
SEC Softening Stance on Cryptocurrency? (May 2018) - FinTech 2018, Monday, August 13, 2018
CFTC Staff Aligns with SEC Position on Initial Coin Offerings: Tokens May Be Commodities (October 2017) - FinTech 2018, Monday, August 13, 2018
SEC Issues Statement on Potentially Unlawful Online Platforms for Trading Digital Assets (March 2018) - FinTech 2018, Monday, August 13, 2018
A CFTC Primer on Virtual Currencies (October 17, 2017) - FinTech 2018, Monday, August 13, 2018
SEC Chairman Issues Major Statement on Cryptocurrency and ICOs (December 2017) - FinTech 2018, Monday, August 13, 2018
Course Handbooks  Course Handbooks Private Fund Regulatory Developments and Compliance Challenges 2018
FinTech 2018
On-Demand Web Programs  On-Demand Web Programs Private Fund Regulatory Developments and Compliance Challenges 2018, Wednesday, February 07, 2018, New York, NY
FinTech 2018, Monday, August 20, 2018, New York, NY
Web Segment  Web Segment BlockChain and Cryptocurrencies – The Global Regulatory Landscape - FinTech 2018, Tuesday, August 14, 2018
MP3 Audio  MP3 Audio BlockChain and Cryptocurrencies – The Global Regulatory Landscape - BlockChain and Cryptocurrencies – The Global Regulatory Landscape, Tuesday, August 14, 2018
Shedding Light on Dark Pools -- The SEC Acts to Increase Transparency and Oversight of Alternative Trading Systems, Thursday, October 25, 2018
Transcripts  Transcripts BlockChain and Cryptocurrencies – The Global Regulatory Landscape - BlockChain and Cryptocurrencies – The Global Regulatory Landscape, Tuesday, August 14, 2018
MP4 - Mobile Video Seg  MP4 - Mobile Video Seg BlockChain and Cryptocurrencies – The Global Regulatory Landscape - BlockChain and Cryptocurrencies – The Global Regulatory Landscape, Tuesday, August 14, 2018
Treatise Chapters  Treatise Chapters Capital Markets and Corporate Finance Activities - Broker-Dealer Regulation (Second Edition), Monday, September 24, 2018
Live Seminar  Live Seminar Private Fund Regulatory Developments and Compliance Challenges 2019, Thursday, January 31, 2019, New York, NY
FinTech 2019, Monday, August 12, 2019, New York, NY
Live Webcast  Live Webcast Private Fund Regulatory Developments and Compliance Challenges 2019, Thursday, January 31, 2019, New York, NY
FinTech 2019, Monday, August 12, 2019, New York, NY
PLI Grpcast-Live Web  PLI Grpcast-Live Web Private Fund Regulatory Developments and Compliance Challenges 2019, Thursday, January 31, 2019, Philadelphia, PA
Private Fund Regulatory Developments and Compliance Challenges 2019, Thursday, January 31, 2019, Pittsburgh, PA
Private Fund Regulatory Developments and Compliance Challenges 2019, Thursday, January 31, 2019, Mechanicsburg, PA
Private Fund Regulatory Developments and Compliance Challenges 2019, Thursday, January 31, 2019, Boston, MA
Private Fund Regulatory Developments and Compliance Challenges 2019, Thursday, January 31, 2019, Indianapolis, IN
Private Fund Regulatory Developments and Compliance Challenges 2019, Thursday, January 31, 2019, Nashville, TN
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