Why Tölt Strategies?
We’re passionate about helping you grow and build for the future.
The Tölt team of independent experts can tailor a solution focused on achieving your goals through efficient allocation of resources and stakeholder management. We utilize bespoke principal-level team structures to ensure effective, efficient solutions.
The Tölt Strategies Team
Tölt Strategies is Proudly Owned and Led by Women
Tel: +1 212-287-5810
Email: dorothy.dewitt@toltstrategies.com
Dorothy D. DeWitt vcard
Education
Harvard Law School, JD
University of Texas at Austin, BA
ACAMS
Public Service
Director of the Division of Market Oversight, CFTC
Chief Finance Counsel – The Honorable Kirsten E. Gillibrand, U.S. Senate (responsible for drafting crypto legislation)
Law Clerk – Honorable John E. Sprizzo, U.S. District Court for the Southern District of New York
Dorothy D. DeWitt is the founder and CEO of independent monitor and compliance advisory firm Tölt Strategies. Her experience regulating and advising companies in emerging and traditional regulated financial services sectors allows her to provide clients with pragmatic, customized solutions that consider the client’s requirements, organization, and culture, among other factors, and are supportive of responsible innovation and growth. Ms. DeWitt recently served as the first woman director of the Division of Market Oversight (“DMO”) at the Commodity Futures Trading Commission (“CFTC”). Ms. DeWitt was responsible for the licensing, regulation, and examination of derivatives trading platforms, and oversaw the approximately $400 trillion notional commodity derivative markets regulated by the CFTC. Ms. DeWitt led a staff of approximately 100 lawyers and economists. She oversaw five departments responsible for regulating and licensing designated contract markets, SEFs, FBOTs, and Swap Data Repositories; examining those entities; and identifying and advising the full Commission on emerging risk, trends, and market structure across regulated derivatives markets and the underlying spot markets to support policymaking and enforcement.
Ms. DeWitt led teams that finalized the CFTC’s last Dodd-Frank rules, and she supported three President’s Working Groups on Financial Markets under two administrations on payment stablecoins and cybersecurity. Ms. DeWitt regularly briefed the White House’s National Economic Council, Congress, Treasury, the SEC, and international regulators and policymakers on emerging risks and issues in the commodity cash and derivative markets. She also led an update of applicable recordkeeping and other rules and issued no-action relief and guidance during the Covid-19 pandemic. Ms. DeWitt was awarded the CFTC Chairman’s Award for Management Excellence in recognition of her accomplishments.
At the request of U.S Senator Kirsten Gillibrand of New York, Ms. DeWitt joined the Senate to provide technical policy expertise in developing crypto legislation and banking policy in the context of the 2023 banking crisis. She served as Chief Finance Counsel to the Senator. Ms. DeWitt joined the CFTC from Coinbase, where she served as General Counsel, supporting the establishment and growth to global leadership of Coinbase Custody and institutional services.
Ms. DeWitt previously served in senior legal and compliance roles at S&P Global, Citadel Securities, JPMorgan and as an attorney at Davis Polk. At S&P Ratings, Ms. DeWitt successfully led a $100 million program to establish a culture of compliance and build an internal control framework in the wake of new Dodd-Frank SEC regulations, financial crimes compliance requirements, and a global SEC and State AG settlement of approximately $1.2 billion involving significant remediation and other undertakings.
At Citadel Securities, Ms. DeWitt led a major program assessing and enhancing the organization’s internal control framework and compliance program, enabling the organization to triple its market share compliantly with no additional headcount. This involved identifying legal and regulatory requirements, mapping and assessing controls against each, enhancing and automating the internal risk and compliance control framework, developing year-round compliance testing programs, and improving the annual compliance report processes for several broker-dealers and a CFTC-registered swap dealer. Previously, Ms. DeWitt spent nearly a decade as a portfolio manager and analyst at arbitrage hedge funds and funds of funds. Ms. DeWitt earned a B.A. from the University of Texas at Austin (summa cum laude, Phi Beta Kappa) and a J.D. from Harvard Law School (cum laude).
Thomas G. Thompson
Thomas G. Thompson
Email: thomas.thompson@toltstrategies.com
Thomas Thompson vcard
Education
University of Minnesota in Agricultural and Applied Economics, MSc
Columbia College, B.A.
Thomas G. Thompson has been contributing to the spectacular growth in derivatives trading since the 1980s as a product designer, economist, and advisor for exchanges and clearinghouses in the United States and Europe. He got his start in the futures industry in the economics division of the CFTC in 1981.
An agricultural economist, Thom joined the Chicago Board of Trade in 1984 and helped bring the first soybean futures options to market in the ag options pilot program.
After that, Thom became a senior product designer in the financial instruments group. There he developed and launched five- and two-year Treasury note futures. He also worked on foreign government bonds, mortgage-backed securities and insurance futures products while at the CBOT.
Lured by the transformative promise of electronic trading, in 1995 Thom and his family moved to Germany, where he worked in international market development for the DTB, later Eurex. As part of his role there, Thom advised exchanges in Bratislava, Budapest, Kyiv and Moscow on how to set up futures trading on behalf of Eurex’s parent company, Deutsche Börse. In 1997, Thom made several presentations to the risk committee of the Russian Central Bank regarding trading on the Moscow Interbank Currency Exchange.
After consulting for the Board of Trade Clearing Corporation, in 2001 he re-joined Eurex, this time in Chicago supporting U.S. market expansion. In 2006, Thom returned to Germany to work on OTC trading and clearing issues, especially assisting on Dodd-Frank Act compliance. Thom became its U.S. CCO in 2011 and guided its application for the U.S. swaps clearing license.
After a few years consulting and writing for John Lothian News, where he headed up crypto reporting, Thom became chief compliance officer at CX Futures Exchange and oversaw its evolution into a full-fledged futures exchange, FMX Futures.
Thomas G. Thompson has been contributing to the spectacular growth in derivatives trading since the 1980s as a product designer, economist, and advisor for exchanges and clearinghouses in the United States and Europe. He got his start in the futures industry in the economics division of the CFTC in 1981.
An agricultural economist, Thom joined the Chicago Board of Trade in 1984 and helped bring the first soybean futures options to market in the ag options pilot program.
After that, Thom became a senior product designer in the financial instruments group. There he developed and launched five- and two-year Treasury note futures. He also worked on foreign government bonds, mortgage-backed securities and insurance futures products while at the CBOT.
Lured by the transformative promise of electronic trading, in 1995 Thom and his family moved to Germany, where he worked in international market development for the DTB, later Eurex. As part of his role there, Thom advised exchanges in Bratislava, Budapest, Kyiv and Moscow on how to set up futures trading on behalf of Eurex’s parent company, Deutsche Börse. In 1997, Thom made several presentations to the risk committee of the Russian Central Bank regarding trading on the Moscow Interbank Currency Exchange.
After consulting for the Board of Trade Clearing Corporation, in 2001 he re-joined Eurex, this time in Chicago supporting U.S. market expansion. In 2006, Thom returned to Germany to work on OTC trading and clearing issues, especially assisting on Dodd-Frank Act compliance. Thom became its U.S. CCO in 2011 and guided its application for the U.S. swaps clearing license.
After a few years consulting and writing for John Lothian News, where he headed up crypto reporting, Thom became chief compliance officer at CX Futures Exchange and oversaw its evolution into a full-fledged futures exchange, FMX Futures.
William F. McCoy
William F. McCoy
Email: william.mccoy@toltstrategies.com
William McCoy vcard
Education
Fordham University, JD
The Wharton School, University of Pennsylvania, B.S.
William F. McCoy is a senior industry professional and trusted advisor with close to four decades of experience advising global financial institutions. His depth of experience across commodities, derivatives, regulatory frameworks, and market infrastructure—combined with his long-standing engagement with regulators and self-regulatory organizations—makes him an exceptional resource for our clients.
During a tenure of more than 30 years, Mr. McCoy served Morgan Stanley in a series of roles of increasing responsibility, culminating as a Managing Director and Global Head of Commodities Legal Coverage. At Morgan Stanley, he oversaw global legal support for commodities trading across exchange-traded and OTC derivatives, physical and financial markets in metals, oil, natural gas, and electricity, and environmental and carbon-related products, including emissions, offsets, and voluntary carbon credits.
Mr. McCoy also contributed his expertise to industry and regulatory bodies for more than 20 years. He served on the U.S. Treasury Department’s Bank Secrecy Act Advisory Group from 2003 to 2007, and he was a member of the Commodity Futures Trading Commission (“CFTC”) Energy & Environmental Markets Advisory Committee from 2008 to 2025. He is a former President of the Law & Compliance Division of the Futures Industry Association (“FIA”), as well as a former board member and long-standing Executive Committee member. In recognition of that service, Mr. McCoy is a 2026 Hall of Fame inductee for FIA.
He was also a director for the National Futures Association (“NFA”) for multiple terms and served on multiple advisory committees of the NFA. Mr. McCoy has also contributed to the work of the International Swaps and Derivatives Association (“ISDA”) and other industry associations focused on derivatives, commodities, and market regulation.
In 2024, Mr. McCoy founded and became the principal of WFM Regulatory Consulting LLC.
Ronald H. Filler
Ronald H. Filler
Email: ronald.filler@toltstrategies.com
Ronald Filler vcard
Education
Georgetown University Law Center, Master of Laws
George Washington University Law School, JD
University of Illinois, B.A.
Ronald H. Filler is an esteemed former Professor of Law and a global leader in the financial services industry. During his 45+ year career in the global futures and securities industries, he has spoken at over 300 business and law programs.
As a professor at four U.S. law schools, he taught Securities Regulation, Derivatives Regulation, and the Regulation of Broker-Dealers and Futures Commission Merchants, among other subjects. In January 2020, Mr. Filler became Professor Emeritus at New York Law School (“NYLS”). In March 2021, he was named Chair of the newly named Ronald H. Filler Institute on Financial Services Law at NYLS. Since then, Mr. Filler has been a Visiting Professor of Law at the College of Law at the University of Illinois the Fall 2023 and Fall 2024 semesters, and a Visiting Professor at the University of San Francisco School of Law.
Mr. Filler is a current member of the Board of Directors of the National Futures Association (“NFA”) where he serves as a Public Director through early 2028. His continued service to NFA includes past membership on the Executive Committee. In March 2022, he was inducted into the Futures Industry Association (FIA) Hall of Fame for serving on the Executive Committee of FIA Law & Compliance Division for 40+ years. Ron has also previously served as the Past Chair of the Commodity Futures Trading Commission’s (CFTC) Global Markets Advisory Committee as a Public Director and Member of the Regulatory Oversight Committee of NYSE Life US, before its purchase by the International Commodity Exchange (“ICE”).
In the private sector, Mr. Filler also currently serves on the Board of Directors of ABAXX Clearing, a clearinghouse located in Singapore. He is the Chair of its Regulatory Oversight Conflicts Committee, a former Public Director of the Board of Directors, and the Chair of the Nominating Committee. Previously, Ron served on the Regulatory Oversight Committee of Swap-Ex, a swap execution facility owned by State Street, and he served as a Senior Consultant to Allen & Overy, a major international law firm. Mr. Filler is currently a member of, or has served on, numerous additional industry boards and advisory committees, as well as been a member of several U.S. futures exchanges during his career.
Mr. Filler joined the faculty of NYLS in 2008. He brought with him fifteen years of experience as the Managing Director in the Capital Markets Prime Services Division of Lehman Brothers Inc., where he was responsible for various business, legal and regulatory matters involving the global futures markets. Prior to joining Lehman Brothers in 1993, he was a Partner and Member of the Executive Committee at Vedder Price Kaufman & Kammholz in Chicago, IL, and worked other law firms and brokerage firms earlier in his career.
Ronald Filler is a co-author of a law treatise on “Regulation of Financial Derivative Instruments (Swaps, Options and Futures)” and has written extensively on a variety of issues facing the financial services, derivatives, and securities industries throughout his career.
Bradley Giemza
Bradley Giemza
Email: Bradley.Giemza@toltstrategies.com
Bradley Giemza vcard
Education
DePaul University, MBA
University of Wisconsin–Milwaukee, B.A.
Bradley Giemza is a seasoned global leader with more than two decades of experience spanning clearing, technology, and risk operations at major financial institutions. Those experiences enabled him to develop expertise in integrating technology solutions with risk management frameworks to support derivatives trading and clearing operations.
Before joining Tölt Strategies, Mr. Giemza was the group chief risk officer and managing director with R.J. O’Brien & Associates, where he was responsible for all emerging technologies and all risk matters, including fintech, agtech, AI, and Data as an Asset. Among other duties, he was responsible for the global risk department and risk technology; the digitizing RJO Risk methodologies and process flows; managing all control and monitoring of algorithmic trading services; and leading the firm’s AI and Data as an Asset research and development.
Prior to his time with R.J. O’Brien, Mr. Giemza was head of investment banking and capital markets IT at MUFG Union Bank. There he was responsible for aligning technology, risk management, and operational objectives across the bank’s interest rate derivatives, commodities, and foreign exchange trading operations.
Earlier in his career, Mr. Giemza founded Neo Risk Management, a platform that assigns accountability and creates transparency to automate process control, regulatory compliance, and corporate governance. Also, he was Global Head of IT for the Newedge Group, a joint venture between Société Générale and Crédit Agricole that operated as one of the world’s largest multi-asset futures and options brokers.
Mr. Giemza is a member of the Global Association of Risk Managers and the Futures Industry Association (FIA).
Rajesh Virassamy
Rajesh Virassamy
Email: Rajesh.Virassamy@toltstrategies.com
Rajesh Virassamy vcard
Education
University of Maryland, MA and MBA
College of Engineering, Guindy (India) B.S.
Rajesh Virassamy is a senior regulatory leader with more than 15 years’ experience across the CFTC and SEC, serving as Senior Swap Consultant/Subject Matter Expert (SME) at both agencies. He has deep expertise in swap regulation, reporting frameworks, and derivatives surveillance across all asset classes and major swap data repositories, and substantial experience conducting forensic data analysis to support enforcement actions, sanctions compliance, and regulatory examinations.
At the SEC, Rajesh was Swap Surveillance Program Consultant in the Division of Examination. Among his responsibilities in this role, he designed and implemented forensic surveillance models for equity swaps and total return swaps; integrated equity order book data with swap positions to detect cross-market manipulation and disruptive trading patterns; led the initiative to ensure timeliness, consistency, completeness and accuracy dimensions are followed in the swap data submission to the Commission; and he analyzed CDS auction reporting data to assess settlement integrity and investigated “manufactured default” scenarios to detect opportunistic credit event triggers.
Prior to that role, Rajesh was Senior Swap Consultant with the CFTC. There, among other duties, he led a cross-divisional rollout of the CFTC 2.0 specification across five asset classes (interest rate swaps (IRS), credit default swaps (CDS), FX, equities and commodities), enabling consistent and accurate swap reporting; led technical analysis for the LIBOR-to-SOFR transition, evaluating the impact on interest rate swap IRS valuations across legacy portfolios; analyzed large-scale datasets to detect potential benchmark rigging and disruptive trading practices, providing critical evidence for enforcement actions; built exposure reports and tracking solutions for the CFTC chairman, covering exposures across products, counterparties, currencies, and tenors; and he directed the cross-divisional rollout of the CFTC 2.0 specification for IRS, CDS, FX, and commodities to ensure accurate regulatory reporting.
Stephen Lurie
Stephen Lurie
Email: stephen.lurie@toltstrategies.com
Stephen Lurie vcard
Education
George Washington University, MBA
Lehigh University, B.A.
Stephen Lurie brings more than 40 years of experience in compliance risk management and internal compliance audits for financial services companies to Tölt Strategies. He has helped banks, broker-dealers, investment firms, their advisers and other financial institutions strengthen compliance frameworks and navigate complex regulatory requirements. With deep knowledge of the Bank Secrecy Act and anti-money laundering requirements, expertise in sanctions administered and enforced by the Office of Foreign Assets Control, and decades of compliance testing experience, Lurie guides clients in achieving and maintaining regulatory compliance.
Among other executive-level roles, Lurie served as director of AML and sanctions at PwC for more than 20 years, where he led engagement teams responsible for establishing, enhancing and remediating BSA/AML and sanctions compliance programs. He also served as executive director and head of BSA/AML and sanctions compliance testing at UBS, where he established and ran the compliance testing unit and developed a BSA/AML and sanctions testing program covering all U.S. business units. Lurie later re-established the anti-financial crimes practice at Dixon Hughes Goodman LLP as the firm’s director and anti-financial crimes leader for two years. Earlier he served as lead international sanctions auditor at Crédit Agricole CIB.
Lurie’s experience includes performing independent program assessments that evaluated control design and tested operational effectiveness; conducting consent order validations of matters requiring attention and matters requiring immediate attention at U.S. and international banks; and completing numerous broker-dealer BSA/AML and OFAC compliance risk assessments. He has conducted Dodd-Frank assessment reviews at regional retail, international and capital markets banks, focusing on consumer and mortgage activities, derivatives and the Volcker Rule. He has also developed policies and procedures covering high-yield bonds and loan syndications, insider and employee trading, front-running, investment adviser codes of ethics, hot issues and suitability.
Mr. Lurie is a Certified Anti Money Laundering Specialist (CAMS) through the Association of Certified Anti-Money Laundering Specialists (ACAMS). CAMS Certificate #ER-000103999. He is also a Certified Cryptocurrency Trader™ (CCT). CCT Certificate #49857692.
Thomas Dunlop
Thomas Dunlop
Thomas Dunlop vcard
Kirke Cushing
Kirke Cushing
Kirke Cushing brings more than 30 years of experience in financial services to Tölt Strategies, with expertise in wealth management, risk and regulatory compliance, M&A due diligence, strategic business development, and go-to-market strategy. He is a well-known subject matter expert (SME) with extensive expert networks and delivers valuable insights to both investors and companies.
In addition to advising Tölt clients, Mr. Cushing serves on the Advisory Board for RipeMetrics, a customer growth platform for small and medium-sized online businesses. He also partners in a global advisory and consulting firm for financial services, specializing in data governance, management, and quality, as well as broader operational and technical innovation, transformation, digitization, and visualization capabilities.
Prior to his current roles, he founded and led Cushing Consulting LLC, served as Chief Operating Officer and Senior Managing Director at Mesirow Financial, and was the US Head of Client Service at Deutsche Bank’s DWS Investments. Mr. Cushing is also a former FINRA industry arbitrator and former member of the Securities Industry and Financial Markets Association (SIFMA) Private Client Committee, reflecting his long‑standing commitment to regulatory integrity and industry best practices.
Jason Fairbanks
Jason Fairbanks
Tel: +1 212-287-5810
Email: jason.fairbanks@toltstrategies.com
Jason Fairbanks vcard
Education
Johns Hopkins University, MA
University of South Carolina Honors College, BA
Jason Fairbanks is a derivatives regulatory advisor and market conduct consultant with over 12 years of experience between the public and private sectors. His expertise combines both quantitative and qualitative evaluations of compliance with diverse regulatory requirements, including swaps regulatory reporting, product listing requirements, and market conduct controls for futures brokers, swap dealers, exchanges, and principal trading firms in traditional and decentralized finance.
Mr. Fairbanks experience in the private sector has spanned independent consultant arrangements remediating regulatory findings, supporting litigation related to new product listings, testing regulatory controls via mock examination, and conducting internal investigations into potential market conduct violations under US, UK, and EU regulations. In the public sector, Mr. Fairbanks has worked with regulators such as the CFTC, SEC, and DOJ on engagements including program design, technical capability development, monitorship oversight, and investigations.
For the SEC Division of Examinations, Mr. Fairbanks helped lead a contractor team designing the SEC’s approach to using mandated security-based swaps reporting. In that role, he provided technical guidance to the SEC on data architecture and quality governance, designed and oversaw implementation of core analytic tools and controls, interfaced with industry on technical swaps reporting issues, and evaluated current events in the swaps market for other SEC divisions.
Earlier, as a member of the CFTC Division of Enforcement Forensic Economics program, under the Office of the Chief Counsel, Mr. Fairbanks served as an in-house analytical expert advising legal teams and investigating market conduct matters resulting in over $750 million in fines. His methods and software expanded the scope, accuracy, and precision of CFTC investigative and trade surveillance capabilities, particularly those involving multi-year spans of data, complex schemes, novel products, or cross-market conduct. Mr. Fairbanks served as a Division of Enforcement representative to working groups innovating new technology solutions and revising swaps regulatory reporting standards. He first joined the CFTC as a contractor providing ad hoc analysis and data science solutions across the agency.
Mr. Fairbanks is a Certified Fraud Examiner (CFE) and previously held the Certified Anti-Money Laundering Specialist (CAMS) designation.
Seth C. Hunter
Seth C. Hunter
Email: seth.hunter@toltstrategies.com
Seth Hunter vcard
Education
George Washington University Law School, Juris Doctorate
Carnegie Mellon University, B.A.
Seth C. Hunter is a financial services professional with over 12 years experience in regulatory advisory services. He has worked extensively with multinational financial services as a management consultant and project manager, working on initiatives at various levels of client sensitivity, timeline, and complexity. Mr. Hunter’s engagements have been driven by everything from new industry-wide regulatory change, client-specific enforcement actions, risk and controls assessments, and various internal initiatives.
Mr. Hunter’s experience as a management consultant for PwC’s advisory practice began in 2013. His initial work was largely driven by clients’ need to adhere to regulations implementing the Dodd-Frank Act, with work projects particularly focused on Title VII and swap-dealer compliance. Since that time his work has included a wide variety of subject matter, including domestic and international regulations, consent orders, and internal initiatives driven by business, operational, or technological changes, engaging with clients based in New York, London, and Charlotte. In support of his client work, he also has experience in business development and thought leadership, driving growth and innovation.
Prior to his time with PwC, Mr. Hunter earned his Juris Doctorate degree from George Washington University Law School. During law school, Mr. Hunter had a number of professional experiences and internships, including work for the Enforcement Division of the SEC, financial services think tanks in the Washington, D.C. area, including Americans for Financial Reform, and the City of Chicago Building Department Enforcement Division. Prior to law school, Mr. Hunter worked as an architect in New York City.
Paul Brochert
Paul Brochert
Email: paul.brochert@toltstrategies.com
Paul Brochert vcard
Education
Georgetown University, MBA
Michigan State University, B.S.
Paul Brochert is a versatile strategy and operations executive with more than 15 years of experience leading complex initiatives across the financial services, management consulting, and technology industries. As a Consultant for Tölt Strategies, he specializes in strategic and tactical projects relating to financial regulation, examination and enforcement response, licensing applications, control testing and validation, and product strategy.
Prior to joining Tölt Strategies, Paul served as Director of Operations for DJC Digital, a buyer-focused digital asset brokerage and M&A advisory firm. He was responsible for designing and implementing new product strategies, AI-driven deal sourcing processes, and a proprietary data analytics infrastructure to deliver actionable M&A intelligence and insights to private equity firms, family offices, and other professional acquirers of software, data, and eCommerce businesses.
Earlier in his career, Paul served as a Manager in PwC’s New York City consulting practice, leading large teams to plan and execute growth strategy, operational optimization, technology transformation, and risk management engagements for Fortune 500 financial services clients. He has extensive experience implementing regulatory compliance initiatives in response to Volcker Rule, Dodd-Frank Act, FINRA 4210, MiFID II, and SEA Rule 15c3-3 legislation.