David E.Aron


Washington + 1.202.879.3876

David Aron is a derivatives lawyer with a blend of private practice, in-house, and government experience. He has extensive transactional and Commodity Futures Trading Commission (CFTC) regulatory experience, including in digital assets and CFTC jurisdictional issues.

David assists clients with, among other things, swap execution facility (SEF) and designated contract market (DCM) registrations and CFTC jurisdictional and compliance issues. His CFTC jurisdictional work includes advising clients on cross-border requirements, event contracts, digital assets, and the appropriate characterization of exposures underlying multi-level proprietary trading strategies as swaps, security-based swaps, mixed swaps, or security options.

Prior to joining Jones Day, David served in various CFTC roles. He was the principal draftsman of, and otherwise influenced, CFTC-SEC (Securities and Exchange Commission) rulemakings further defining "swap" and "eligible contract participant." He also served as liaison to the CFTC's Division of Enforcement in multiple swap-related investigations and was detailed to the Office of the Chief Economist and the U.S. Department of the Treasury.

Earlier in his career, he worked in the United Nations Treasury. David began his career in the securities investments unit of the law department at a global insurance company followed by a role supporting the equity, credit, and other derivatives business at a global bank. He also worked at three major law firms, including as partner, where he advised clients in CFTC and SEC regulatory, investment management, energy trading, structured products, and various derivatives matters.

David is a frequent speaker and author on CFTC regulatory issues, including sports betting and cryptocurrency. He also serves as a resource to veterans transitioning to civilian legal roles.


  • Energy trading firm seeks assistance drafting CFTC section of its compliance manualJones Day drafted the CFTC section of an energy trading firm's compliance manual.
  • Swap dealer and security-based swap dealer receives advice related to CFTC swap reporting and SEC security-based swap reportingJones Day is advising a swap dealer and security-based swap dealer with CFTC swap reporting and SEC security-based swap reporting regulatory advice on various matters.
  • Swap dealer receives advice related to financial product characterizationJones Day is advising a swap dealer in connection with appropriate characterization of various trading strategies and products as (1) swaps, (2) security-based swaps, (3) mixed-swaps, (4) securities, or (5) other products.
  • Energy trading firm seeks review of CFTC section of its compliance manual and CFTC regulatory adviceJones Day reviewed and suggested revisions to the CFTC section of an energy trading company's compliance manual.