Dorothy D. DeWitt

Biography

Dorothy DeWitt is the founder and CEO of Tölt Strategies, LLC. Under Dorothy's leadership, Tölt operates as a high-authority advisory firm focused on digital assets; perpetual, prediction, RWA trading and markets; GPU compute capacity and model inference futures and forwards trading and markets and benchmark index creation and governance. Tölt specializing in securities, commodity, and commodity derivative trading and markets and infrastructure innovation. Tölt advises early-stage startups, including current and former Y Combinator and similar accelerator companies, companies experiencing hypergrowth, and established companies. Past and current work include guiding clients through complex lifecycle decisions, advising companies on optimal operating structures and regulatory strategy. Tölt has also assisted clients through the process of registering their platforms as with the SEC and CFTC, seeking relief where necessary (recently in the perpetual space) as well navigating exemptions and exclusions from registration, when available. Tölt's practice bridges high-level business strategy with rigorous regulatory execution to streamline fund launches, minimize ongoing compliance overhead, and maintain institutional-grade governance.

Throughout Dorothy's career, she has been a leader in support of responsible innovation, customer protection, market integrity, and the prevention of illicit finance in both government service and executive roles in the private sector. Prior to founding Tölt Strategies, Ms. DeWitt served as the Director of the Division of Market Oversight under CFTC Chairmen appointed by both Republican and Democrat administrations. There she oversaw teams that registered, regulated, and examined commodity derivative exchanges and swap data repositories, developed policy and rulemaking, and analyzed emerging risks and trends in the spot and derivatives markets. Her team was responsible for advising the Commissioners and all divisions on policy, market surveillance, and market structure. Ms. DeWitt trained the full Commission staff in blockchain and crypto, enabling the CFTC to regulate the crypto derivatives market and to take on new jurisdiction under recently proposed legislation. 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.

Also at the CFTC, Ms. DeWitt supported the President’s Working Group on Financial Markets, helping to refine policy and to draft two reports:

• President’s Working Group on Financial Markets Releases Statement on Key Regulatory and Supervisory Issues Relevant to Certain Stablecoins (December 2020)

• President’s Working Group on Financial Markets Releases Report and Recommendations on Stablecoins (November 2021).

In another government service role, Ms. DeWitt served as Chief Finance Counsel to Senator Kirstin E. Gillibrand. In this role, Ms. DeWitt drafted and negotiated pragmatic bipartisan legislative solutions that recognized crypto innovation while protecting vital national security, trading and market, and customer and investor interests.

In the private sector, Ms. DeWitt has held executive roles in the financial services industry and as an attorney at Davis Polk. As General Counsel for Products and Markets at Coinbase, Ms. DeWitt helped lead Coinbase Custody from inception to becoming the world’s largest crypto custodian. She advised global products and business lines in innovating and expanding in compliance with BSA/AML and sanctions obligations, among other responsibilities. She managed a global team across North America, Europe, and Asia that advised on building exchange, prime brokerage, and OTC businesses, staking services, EARN rewards, and a custodial business in the context of federal, state, and international legal and regulatory requirements.

Prior to that role, Ms. DeWitt served as COO of Legal & Compliance at Citadel Securities, a broker-dealer and swaps dealer, where she led a program to enhance and automate controls that enabled Citadel Securities to triple its market share compliantly and with no additional headcount. Previously, Ms. DeWitt served in senior legal and compliance roles at S&P Global and JPMorgan. At S&P Global she led a $100 million dollar program to establish a culture of compliance and build an internal control framework in the wake of new Dodd-Frank SEC regulations and a global SEC/state AG settlement of approximately $1.2 billion involving significant remediation and other undertakings.