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
Education
University of Texas at Austin, BA
Harvard Law School, JD
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 (DCMs), swap execution facilities (SEFs), and swap data repositories (SWAPs) by 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 the team that licensed and regulated Kalshi, the first federally registered prediction market, addressing unprecedented regulatory challenges at the forefront of today’s public and policy debates.
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 Securities Exchange Commission (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 BA from the University of Texas at Austin (summa cum laude, Phi Beta Kappa) and a JD from Harvard Law School (cum laude).
Bill McCoy
Bill McCoy
Email: william.mccoy@toltstrategies.com
Education
The Wharton School, University of
Pennsylvania, BS
Fordham University, JD
William F. McCoy (Bill) is a senior industry professional and trusted advisor with 40 years’ 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, Bill served Morgan Stanley in a series of roles with 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.
Bill 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 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, Bill is a 2026 Hall of Fame inductee for FIA.
Bill served as director for the National Futures Association (NFA) for multiple terms and served on multiple advisory committees of the NFA. Bill has also contributed to the work of the International Swaps and Derivatives Association and other industry associations focused on derivatives, commodities, and market regulation.
In 2024, Bill founded and became the principal of WFM Regulatory Consulting, LLC.
Richard Jaycobs
Richard Jaycobs
Email: rich.jaycobs@toltstrategies.com
Education
Columbia University, School of Engineering
and Applied Science, BS
Richard Jaycobs (Rich) has extensive experience in exchange and clearinghouse operations, technology, and regulatory matters. From 2007 until 2021 Rich was President and CEO of Cantor Exchange, Cantor Clearinghouse, and ELX Futures.
Rich was CEO of The Clearing Corporation (formerly the Chicago Board of Trade Clearing Corporation) between 2005 and 2007 and, from 1999 through 2005, he was founder and CEO of onExchange, the first fully approved non-intermediated, straight-through-processing, direct-to-retail DCM and DCO registered by the CFTC.
Currently, Rich facilitates applications for DCMs and DCOs based on best practices, related operating strategies, and technical considerations. As principal or advisor, Rich has provided material strategic, operational, and regulatory support for seven approved DCM applications and six approved DCO applications and several pending applications.
Rich has advised international marketplaces in Europe, Asia, Africa, and the Middle East on binary options, agricultural, and financial derivatives. He received U.S. regulatory approval to trade event contracts short-duration digital options, pin-drop weather contracts, bitcoin contracts, and parimutuel payout contracts.
Rich is familiar with the system safeguard requirements as specified in Part 38 and Part 39 of the Commodity Futures Trading Commission regulations and has participated in system safeguard and risk management briefings required under those parts.
Rich is the author of several industry publications on new markets and market liquidity and was the co-editor of the anthology book, From Black-Scholes to Black Holes: New Frontiers in Options.
Ron Filler
Ron Filler
Email: ronald.filler@toltstrategies.com
Education
University of Illinois, BA
Georgetown University Law Center, LLM
George Washington University
Law School, JD
Ronald H. Filler (Ron) is a former Professor of Law and a Director of the Financial Services Law Institute at New York Law School (NYLS), located in New York City. He became a Professor Emeritus at NYLS in January 2020. In March 2021, he was named Chair of the newly named Ronald H. Filler Institute on Financial Services Law at NYLS. He has taught several courses involving the financial services industry at four different U.S. law schools over the past 45+ years including, among others, Securities Regulation, Derivatives Regulation and the Regulation of Broker-Dealers, and Futures Commission Merchants.
Prior to joining the faculty of NYLS in 2008, he was a Managing Director in the Capital Markets Prime Services Division at 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, a large law firm located in Chicago, IL, and worked at various other law firms and brokerage firms earlier in his career. He is currently a member of, or has served on, numerous industry boards and advisory committees, including serving on the Executive Committee of the Futures Industry Association (FIA) Law & Compliance Division for the past 40+ years.
In March 2022, he was inducted into the FIA Hall of Fame. He is currently a Member of the Board of Directors and a past member of the Executive Committee of the National Futures Association (NFA) where he serves as a Public Director and has served, or currently serves, on several NFA Committees; a Public Representative on the Board of Director of ABAXX Clearing, a clearinghouse located in Singapore and is the Chair of its Regulatory Oversight Conflicts Committee; and a former Public Director of the Board of Directors, and Chair of the Nominating Committee and of the Regulatory Oversight Committee, of Swap-Ex, a swap execution facility owned by State Street.
Ron previously served as the 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, and served as a Senior Consultant to Allen & Overy, a major international law firm. Ron has been a member of several U.S. futures exchanges during his career and has spoken at over 300 business and law programs during his 45+ year career in the global futures and securities industries.
Ron is a co-author of a law treatise, 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.
Bill Harrington
Bill Harrington
Email: bill.harrington@toltstrategies.com
Education
University of Illinois, BS
University of Notre Dame, MBA
William Harrington (Bill) has more than three decades’ experience in the financial services industry, and he has deep experience providing audit, risk and controls services. Prior to joining Tölt Strategies, Bill served as the Managing Director and Global Head of Internal Audit for R.J. O’Brien & Associates where he was responsible for the delivery of the Internal Audit plan in Chicago, London, Dubai, Paris and Singapore. Bill also served as the Chairman of the firm’s Technology Risk Committee which provided a direct line of site to the technology risk areas including Information Security and Operational Resiliency.
Bill served as a Partner in the Risk Assurance practice of PricewaterhouseCoopers (PwC) in Chicago. In this role he provided clients with services from both an external and internal audit perspective as well as SOC reporting services for organizations who wanted to provide third-party assurance to their constituents. He also has experience leading IT Security assessments and providing Business Continuity Planning/Disaster Recovery Planning services. In addition, Bill has extensive experience in assessing and reporting on internal controls, having served as a Sarbanes-Oxley specialist for organizations as they prepared for their annual 404 attestation.
Bill has been involved with the ISACA Chicago Chapter on their Board of Directors as well as the Board of the Risk Management Association in Chicago. He also served on two advisory boards for the Mendoza College of Business at the University of Notre Dame, one for the Accounting department and the for the IT, Analytics and Operations department.
Bill holds several certifications in risk and controls including Certified Information Systems Auditor (CISA), Certified in the Governance of Enterprise IT (CGEIT), and Certified in Risk and Information Systems Controls (CRISC).
Bradley Giemza
Bradley Giemza
Email: bradley.giemza@toltstrategies.com
Education
University of Wisconsin–Milwaukee, BA
DePaul University, MBA
Bradley Giemza (Brad) is a seasoned global leader with more than two decades’ experience spanning clearing, technology, and risk operations at major financial institutions where he has established expertise in integrating technology solutions with risk management frameworks to support derivatives trading and clearing operations.
Before joining Tölt Strategies, Brad 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, and artificial intelligence (AI). Among other duties, he was responsible for the global risk department and risk technology; 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.
Before his time with RJO, Brad 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, Brad founded Neo Risk Management, a platform that assigns accountability and creates transparency to automate process control, regulatory compliance, and corporate governance. 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.
Brad holds the Series 99 license, which qualifies him for compliance roles with futures brokerage firms, and he is a member of the Global Association of Risk Managers and the Futures Industry Association (FIA).
Brent Cantley
Brent Cantley
Email: brent.cantley@toltstrategies.com
Education
University of Washington, BA, International Relations
Brent Cantley is a senior-level professional with over two decades’ experience in nonprofit management, government, and regulatory environments. He has established expertise in operations, supervision, and legal support within federal agencies and professional associations, demonstrating a consistent ability to manage complex projects and foster key relationships.
Most recently, Brent served as a Contractor for the Commodity Futures Trading Commission (CFTC). In this role, he was instrumental in the prosecution of financial fraud cases, particularly those involving cryptocurrency, by directing investigative matters, and proofreading and editing key legal documents. His work contributed to the recovery of hundreds of millions of dollars. Additionally, he managed the agency’s internship program, mentoring and placing over 200 interns.
Prior to his work with the CFTC, Brent was a Manager at the Association of Fundraising Professionals Foundation for Philanthropy. There, he managed a $12 million foundation, handled donor relations for endowment funds, and liaised with the Board of Directors. He also developed communications, including newsletters and documents for the Executive Vice President. Earlier in his career, Brent held progressive roles in sales management and client relations, and was Chief of Staff/Board Liaison for Reading Is Fundamental.
Debbie Ferrara
Debbie Ferrara
Debbie Ferrara has extensive compliance experience including working in law enforcement and serving as a financial crimes compliance executive as well as on behalf of regulators to address identified compliance deficiencies. Her experience includes serving as an independent monitor for the New York Department of Financial Services, as well as the Federal Reserve Bank of New York. Debbie has also worked to address insufficient controls identified by the Office of Comptroller of the Currency.
Her expertise includes conducting annual BSA/AML and OFAC Risk Assessments to inventory controls and identify the residual risks not within the institution’s risk appetite and developing action plans to address the risk; developing policies and procedures to address the BSA/AML regulatory requirements on behalf of international financial institutions with a presence in the US; conducting Know Your Customer (KYC) remediations; transaction monitoring, conducting investigations, historical look-backs, as well as Suspicious Activity Reporting (SAR) writing; investigations and historic analyses/look-backs; working on a joint terrorism task force to identify money laundering schemes to fund terrorist operations; and project management and quality assurance reviews.
Debbie’s professional experience includes various multi-national financial institutions, broker dealers, banking as a service, money service businesses, and community banks. Past employers and clients include Guidehouse, Navigant Consulting, the Federal Bureau of Investigation, Federal Emergency Management Agency, JPMorgan Chase, Cross River Bank, Credit Suisse, Standard Chartered Bank, Wells Fargo, UBS, Bank of Tokyo-Mistibushi UFJ, Interactive Brokers, Intesa Sanpaolo, TD Bank, and Nordea Bank.
Etleva Skenderi
Etleva Skenderi
Email: etleva.skenderi@toltstrategies.com
Education
University of Tirana, Albania, BSc,
Mathematics
University of Strathclyde, UK, MSc,
Finance
Etleva Skenderi (Eva) is a senior leader with more than 20 years’ experience driving large-scale transformation across technology, operations, and risk.
She also has deep expertise in data strategy, analytics, and complex program delivery.
Most recently, Eva was Director, Global Technology and Operations, at Société Générale in Chicago. In that role, she led global transformation, modernizing data, technology, and operations across front-to-back functions; delivered large-scale automation initiatives; directed global reorganization and cost-efficiency programs; enabled regulatory and market structure initiatives; and partnered with senior stakeholders across Trading, Risk, and Operations to define and execute a multi-year strategic roadmap.
Before her work with Société Générale, Eva was Senior Quantitative Analyst at Bank of America, where she led industrialization of a proprietary Credit Valuation Adjustment platform, transforming it into a scalable, enterprise-grade pricing and risk system; partnered across Trading, Risk, Finance, and Technology to deliver integrated valuation and risk analytics capabilities; and supported Federal Reserve stress testing initiatives, enhancing model governance, controls, and regulatory compliance.
Prior to her work at Bank of America, Eva was a Senior Quantitative Analyst at ABN AMRO, a Senior Quantitative Analyst at Hedge Fund Research, a Quantitative Analyst at Manulife Financial, and a Scientific Researcher at University of Strathclyde.
She is a certified Financial Risk Manager (FRM) from Global Association of Risk Professionals (GARP).
Everett Samms
Everett Samms
Everett H. Samms, MSG, USAR (Ret.), is a senior financial-markets leader with more than 30 years’ experience across futures trading, derivatives markets, credit risk, market risk, margin operations, and regulatory oversight. He has built and led enterprise risk frameworks for some of the industry’s most established brokerage and futures organizations, possessing deep expertise spanning institutional, commercial, and retail market participants. His professional background integrates operational oversight and technology-enabled risk management, a combination shaped by a strategic mindset and a disciplined, mission-focused approach developed over three decades of military service.
Most recently, Everett served as Executive Director of Risk – North America at R.J. O’Brien & Associates, where he led regional risk strategy and oversaw daily exposure monitoring, margin adequacy, and counterparty risk assessment. In this role, he chaired the firm’s Risk Management Unit and was instrumental in modernizing operational risk processes through the implementation of real-time risk analytics and integrated dashboards. Prior to this, he served for nearly two decades as Senior Director and Head of Credit at RJO, directing firmwide credit risk governance, onboarding controls, and exposure oversight while balancing disciplined risk management with business growth objectives.
Earlier in his career, Everett held senior leadership positions at Refco and PaineWebber, where he managed teams focused on client onboarding, documentation, margin exposure limits, and financial analysis. He also contributed to the design and development of Credit Limit and Line Exception Reporting systems that enhanced risk transparency and operational efficiency. His broad experience extends to legal structures, vendor oversight, and multi-state operational management, where he has guided organizations through complex markets and governance challenges.
In addition to his financial expertise, Everett served with distinction in both the U.S. Air Force Reserve and U.S. Army Reserve, retiring as a Master Sergeant after 30 years’ service. His military leadership included operational, instructional, and advisory assignments—including aircraft maintenance and service in support of Operation Iraqi Freedom—and he is the recipient of multiple commendations recognizing his leadership and operational excellence. He is widely recognized for his strategic mindset and his ability to build robust risk frameworks that align operational efficiency with regulatory expectations.
Jason Fairbanks
Jason Fairbanks
Email: jason.fairbanks@toltstrategies.com
Education
University of South Carolina
Honors College, BA, International Studies
The Johns Hopkins University, MA,
Applied Economics
Jason Fairbanks is a derivatives regulatory advisor and market conduct consultant with more than 12 years’ experience in both 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. At Tölt Strategies, Jason specializes in regulatory advisory related to trading and markets.
Jason’s 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 U.S., U.K., and European regulations.
In the public sector, Jason has worked with regulators such as the CFTC, SEC, and DOJ on engagements including program design, technical capability development, monitorship oversight, and investigations. He helped to lead a contractor team designing the SEC’s approach to using mandated security-based swaps reporting for the SEC Division of Examinations. 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 in this career, as a member of the CFTC Division of Enforcement’s Forensic Economics program, under the Office of the Chief Counsel, Jason 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, and cross-market conduct. He 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.
Jason is a Certified Fraud Examiner (CFE) and previously held the Certified Anti-Money Laundering Specialist (CAMS) designation.
Jay Carroll
Jay Carroll
Jay Carroll is a management consultant with more than a decade of experience leading complex initiatives across the financial services, federal government, and fintech industries. At Tölt Strategies, he specializes in regulatory advisory projects relating to trading and markets and supports the firm across business and compliance advisory, internal controls, and operations.
Prior to joining Tölt Strategies, Jay served as a Manager with Clarendon Partners, leading a data automation platform implementation for a global asset manager that automated document intake and data workflows for alternative asset operations. He designed a SOC-compliant controls framework, built CIO-level reporting dashboards, and established Steering Committee governance.
Earlier in his career, Jay served as a Principal Management Consultant at M2 Strategy, where he developed risk management frameworks to assess system functional maturity, identify control gaps, and strengthen operational resilience for a large federal entity. As a Senior Consultant at Sia Partners, he led requirements gathering and integration analysis for a new offshore mutual fund trading product.
Kirke Cushing
Kirke Cushing
Kirke Cushing brings more than 30 years’ experience in financial services to Tölt Strategies, with expertise in wealth management, risk and regulatory compliance, mergers & acquisitions due diligence, strategic business development, and go-to-market strategy. He is a well-known subject matter expert with extensive expert networks and delivers valuable insights to both investors and companies.
In addition to advising Tölt clients, Kirke serves on the Advisory Board for RipeMetrics, a customer growth platform for small and medium-sized online businesses. Kirke 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 U.S. Head of Client Service at Deutsche Bank’s DWS Investments. Kirke is also a former FINRA industry arbitrator and former member of the SIFMA Private Client Committee, reflecting his long‑standing commitment to regulatory integrity and industry best practices.
Kirke holds a Certificate in Financial Planning from DePaul University.
Paul Brochert
Paul Brochert
Email: paul.brochert@toltstrategies.com
Education
Michigan State University, BS, Finance
Georgetown University, MBA,
International Business
Paul Brochert is a versatile strategy and operations executive with more than 15 years’ experience leading complex initiatives across the financial services, management consulting, and technology industries. At 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 mergers and acquisitions advisory firm. He was responsible for designing and implementing new product strategies, artificial intelligence (AI)-driven deal sourcing processes, and a proprietary data analytics infrastructure to deliver actionable mergers and acquisition 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 PricewaterhouseCooper (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.
Rajesh Virassamy
Rajesh Virassamy
Email: rajesh.virassamy@toltstrategies.com
Education
College of Engineering, Guindy (India), BS
University of Maryland, MS, Computer
Systems Management, and MBA, Finance
Rajesh Virassamy is a senior regulatory leader with more than 15 years’ experience across the CFTC and SEC, serving as Senior Swap Consultant/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 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, credit default swaps, 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 directed the cross-divisional rollout of the CFTC 2.0 specification for IRS, CDS, FX, and commodities to ensure accurate regulatory reporting.
Ritu Dayal
Ritu Dayal
Ritu Dayal is a seasoned corporate finance executive with more than two decades’ leadership driving financial strategy, operational transparency, and enterprise value across the global financial services sector. As a trusted advisor to executive boards and C-level leadership, she specializes in aligning complex financial structures with long-term corporate growth. Throughout her career, she has built a distinguished reputation for transforming financial systems, optimizing capital allocation, and spearheading high-impact corporate development initiatives that maximize profitability and stakeholder value.
Before joining Tölt, Ritu served as the Senior Director of Financial Planning & Analysis for R.J. O’Brien & Associates, navigating the firm through its high-profile acquisition by StoneX Group Inc. (a Fortune 50 company). In this capacity, she directed global financial planning across multiple geographies and diverse revenue streams, translating intricate operational data into actionable expansion strategies. Notably, she orchestrated the comprehensive financial due diligence and post-merger integration for the acquisition, securing seamless synergy realization while preserving capital.
Prior to her tenure with RJO and StoneX, Ritu held key financial leadership roles at prominent global institutions, including Gain Capital Group, MF Global, and Bank of America. Her executive track record includes managing multi-million-dollar budgets, structuring complex corporate credit portfolios, and executing debt covenant modifications to fortify liquidity.
Ritu is dually credentialed as a licensed Certified Public Accountant (CPA) in Illinois and a Chartered Accountant (CA) in India, combining elite analytical standards with a forward-looking financial vision.
Ron Breitigam
Ron Breitigam
Ron Breitigam is a venerable investment and trading executive with more than four decades’ experience spanning digital assets, alternative investments, quantitative trading, and financial technology. He advises emerging managers, crypto lenders, fintech companies, and institutional investors on strategy, operations, manager selection, and business growth. Throughout his career, Ron has built, scaled, and operated investment platforms across traditional and digital asset markets, combining deep market expertise with extensive operational and regulatory experience.
Since 2020, Ron has provided digital asset advisory services, supporting clients across the cryptocurrency and fintech ecosystem. His work has included leading trading and operational functions for a global crypto investment platform, conducting due diligence on quantitative trading managers, providing outsourced COO services to digital asset funds, and advising fintech firms through strategic transactions.
Prior to focusing on digital assets, Ron founded and managed a quantitative energy-focused commodity-trading advisor, and held leadership roles at firms including SparkCognition, Lake Austin Advisors, and Eclipse Capital. At SparkCognition, he led financial services business development for artificial intelligence solutions serving hedge funds, trading firms, banks, and exchanges. At Eclipse Capital, he served as Chief Operating Officer of a $500 million commodity trading advisor, overseeing business development, trading, technology, compliance, finance, and recruiting functions.
Earlier in his career, Ron spent nearly two decades leading trading operations and managing global futures, foreign exchange, and equity trading activities. He began his financial markets career as a trader and exchange member in Chicago before holding positions with Thomson McKinnon, Paine Webber, and his own proprietary trading firm. His experience spans multiple market cycles and includes extensive work with institutional investors, family offices, sovereign wealth funds, and alternative investment managers.
Ron is a Chartered Alternative Investment Analyst (CAIA). He also maintains FINRA Series 65 and NFA Series 3 registrations.
Seth C. Hunter
Seth C. Hunter
Email: seth.hunter@toltstrategies.com
Education
Carnegie Mellon University, BA
George Washington University Law
School, JD
Seth C. Hunter has more than 12 years’ experience in financial services working with clients on engagements focused on regulatory advisory services, including new industry-wide regulatory change, client-specific enforcement actions, risk and controls assessment, and various internal initiatives. At Tölt Strategies, Seth manages complex and sensitive project deliverables, supports strategic planning, and works with stakeholders to identify challenges and proactively mitigate potential risks. By combining legal expertise with strategic advisory skills, he guides organizations through issues involving commodity futures, derivatives, and securities to help them mitigate risk, ensure compliance, and capture opportunities for sustainable growth.
Prior to joining Tölt Strategies, Seth worked as a Management Consultant for PricewaterhouseCooper (PwC)’s advisory practice, where he served clients in the United States and London on a wide variety of subjects, including domestic and international regulations, consent orders, and initiatives driven by business, operational, and technological changes. Also at PwC, he advised clients on the implementation of the Dodd-Frank Act, with particular focus on Title VII and swap-dealer compliance.
While attending law school, Seth worked for the Enforcement Division of the SEC, the City of Chicago Building Department Enforcement Division, and for D.C.-based financial services think tanks, including Americans for Financial Reform. Seth worked as an architect in New York before entering law school.
Stephen Lurie
Stephen Lurie
Email: stephen.lurie@toltstrategies.com
Education
Lehigh University, BA, Economics
George Washington University, MBA,
Finance and Investments
Stephen Lurie is a compliance risk management and internal compliance audit professional with more than 40 years’ experience. 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 (BSA) and anti-money laundering (AML) requirements, expertise in sanctions administered and enforced by the Office of Foreign Assets Control, and decades of compliance testing experience, Stephen guides clients in achieving and maintaining regulatory compliance.
Beginning in 1997 and continuing for more than 20 years, Stephen served as director of AML and sanctions at PricewaterhouseCoopers (PwC), where he led engagement teams responsible for establishing, enhancing, and remediating BSA/AML and sanctions compliance programs.
After PwC, Stephen 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. Stephen later re-established the anti-financial crimes practice at Dixon Hughes Goodman, LLP, as the firm’s Director and Anti-Financial Crimes leader for 2 years.
Just prior to joining Tölt, Stephen was an international sanctions auditor at Crédit Agricole CIB, where he performed audit validations of BSA/AML remediation efforts of Matters Requiring Attention from the Federal Reserve and the New York State Department of Financial Services.
Stephen is a Certified Anti Money Laundering Specialist through the Association of Certified Anti-Money Laundering Specialists and a Certified Cryptocurrency Trader™.
Thomas Dunlap
Thomas Dunlap
Thomas Dunlap (Tom) brings more than 36 years’ financial services experience focused on a range of business and functional capabilities to Tölt Strategies. He specializes in data governance, management, and quality, as well as broader operational and technical innovation, transformation, digitization, visualization, risk management, and regulatory conformance. His specialty includes significant exposure to broker/dealer front-to-back trading lifecycle activities.
Earlier in his career, Tom was Group Chief Data Officer of the London Stock Exchange Group. In that role, he was responsible for developing and executing the strategic frameworks for enterprise data governance, master data management, records management, and data insight and analysis. He also served in several senior operations and data leadership roles at Goldman Sachs for 18 years, culminating as Managing Director of Operations and Global Head of Enterprise Data Strategy.
Showing his commitment to effective growth and best practices in the industry, Tom has contributed his expertise to industry groups and government committees. Currently, he is a Senior Fellow with the Data Foundation, and he serves on the advisory board for DeepSee.ai. Previously, Tom was a two-term member of the Financial Research Advisory Committee of the U.S. Treasury Department’s Office of Financial Research, and he served on the Board of Directors of the Enterprise Data Management Council.
Tom was Americas Regional Head of Options and Futures Trade Management with responsibility for the post-trade lifecycle of listed options and futures transactions for Goldman Sachs’ acquisition of Spear, Leeds, and Kellogg. He managed trade processing, clearing and settlement coordination, position reconciliation, expiration and exercise activities, regulatory compliance, and risk management functions. In addition, he worked closely with exchanges, clearing organizations, traders, and other operations teams to ensure accurate trade capture, position management, and contract settlement across the equity, index, and futures product types.