Joshua B.Sterling (Josh)


ワシントン + 1.202.879.3769

Josh Sterling is a leading practitioner in commodities and derivatives law. He helps banks, fintechs, corporations, and several of the world's largest trading platforms successfully address enforcement, regulatory, and transactional matters that are of strategic importance to their businesses.

Josh's practical advice is informed by his tenure in leadership at the Commodity Futures Trading Commission (CFTC), the primary U.S. regulator of the derivatives markets. At the CFTC, Josh played an instrumental role in completing the remaining rulemakings required by the Dodd-Frank Act, as well as in charging and settling several groundbreaking enforcement actions.

As Director of the CFTC's Market Participants Division, Josh oversaw the 3,300-plus banks, intermediaries, and asset managers registered with the agency to trade derivatives in U.S. markets. He was responsible for the CFTC's examination, rulemaking, and enforcement referral programs governing those firms. Josh also was the federal official responsible for oversight of the National Futures Association (NFA), the self-regulatory body for CFTC-registered firms and individuals. For his record-setting accomplishments at the CFTC, Josh received the Chairman's Award for Excellence in Management.

Josh regularly assists major derivatives exchanges, market participants, and fintechs with obtaining approvals for new product and business initiatives through engagement with the regulators and by executing on their strategic business initiatives.

Josh has extensive experience representing clients in CFTC and SEC enforcement investigations, as well as in examinations of their trading activities and regulatory compliance brought by NFA and derivatives exchanges. He has successfully resolved several cases for corporate and individual defendants.


  • Kalshi files challenge to CFTC order rejecting listing of its Congressional Control ContractsJones Day is representing KalshiEX LLC (Kalshi) in litigation against its regulator, the Commodity Futures Trading Commission (CFTC), challenging the CFTC's recent order to prohibit Kalshi from listing certain political event contracts on its regulated derivatives exchange.
  • Principal trading firm receives advice on relevant exchange rules and other authority governing cryptocurrency futures tradingOn behalf of a principal trading firm, Jones Day examined exchange rules most relevant to trading cryptocurrency futures and ETF options.
  • Financial institution receives swap dealer compliance manual adviceOn behalf of a financial institution, Jones Day reviewed a swap dealer compliance manual for legal sufficiency and advised on product characterization, foreign exchange swaps and forwards, and eligible contract participant issues.
  • 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.
  • Client obtains declination in CFTC Enforcement Division investigationJones Day obtained a declination from the CFTC Enforcement Division on behalf of an individual client who was under investigation for alleged retail foreign exchange ("forex") trading fraud and associated registration violations.
  • DraftKings launches sports-memorabilia NFT marketplace in U.S.Jones Day is advising DraftKings Inc. on regulatory and legal matters related to the launch of a sports-memorabilia NFT marketplace in the United States.
  • Procter & Gamble enters into two 15-year virtual power purchase agreements with EDPR for solar and wind energy in EUJones Day advised The Procter Gamble Company in entering into two 15-year virtual power purchase agreements (VPPAs) to purchase electricity and guarantees of origin (GOs) from solar and wind energy projects in the EU owned by a subsidiary of renewable energy developer EDP Renováveis, S.A. (EDPR).
  • 講演

    • June 2021
      NFTs: Key Considerations for an Emerging Asset Class, Futures Industry Association Member Event