Charles R. Mills

Charley Mills counsels and represents a diverse mix of professional intermediaries, traders, and end users in the derivatives, commodities, and securities markets. His practice focuses on enforcement defense and regulatory issues before the Commodity Futures Trading Commission (CFTC), the Federal Energy Regulatory Commission (FERC), the US Securities and Exchange Commission (SEC), the self-regulatory organizations of those industries, and the federal courts.

The great majority of investigations of his clients have concluded without initiation of any charges, and he has prevailed for clients in more than 60 administrative proceedings, trials, arbitrations, and appeals. Charley brings to each matter not only a deep understanding of the law, but also knowledge of the market dynamics of trading, which often are critical to the proper application of the law.

He has dealt with many different traded products, including, among others, electric power, oil and gas, agricultural commodities, metals, forex, virtual currencies, and securities. In complex regulatory and compliance matters, Charley often teams with Steptoe’s deep bench of other regulatory lawyers to deliver comprehensive advice, training, and advocacy. Charley’s work is informed by his years as a litigator and regulatory attorney at the CFTC.

Typical client regulatory issues include registration, requests for no-action letters and other exemptive relief, and proposed agency rules. Recent matters have involved swaps trading and reporting, initial cryptocurrency coin offerings and trading, and blockchain usage. His clients include, among others, energy and other operating companies, investment funds and other financial entities, proprietary traders, trade associations, registered advisers, entrepreneurs, and their directors, officers, and employees.

Charley is a former Chair of the American Bar Association’s Derivatives and Futures Law Committee and has long served on the New York City Bar’s Committee on Futures and Derivatives Regulation. He has served multiple terms on the Executive Committee of the Law and Compliance Division of the Futures Industry Association.

Charley is a frequent speaker at law conferences and has written widely on derivatives and securities law, including co-authoring Derivatives Regulation – 2018 Cumulative Supplement (Wolters Kluwer), Broker-Dealer Regulation (PLI, 2016), and The Securities Enforcement Manual (ABA, 2007). He is on the Board of Editors of the Futures & Derivatives Law Report, and was an adjunct faculty professor at Georgetown University Law Center for 21 years, teaching courses in derivatives regulation and securities law.

In addition to his legal practice, Charley serves as president of the foundation that supports the Benedictine School for Exceptional Children Inc., which provides educational, vocational, and residential services to individuals with developmental disabilities.