Pamela Geraghty

Senior Director

750 17th Street NW, Suite 1000, Washington, D.C. 20006

Ms. Geraghty offers clients unique and pragmatic insight into Commodity Futures Trading Commission (CFTC) matters by bringing a deep understanding of complex regulatory requirements in the derivatives space. Ms. Geraghty’s expertise includes the registration and oversight of CFTC intermediaries – such as swap dealers, futures commission merchants, and introducing brokers – as well as risk management, reporting, business conduct standards, recordkeeping, communications surveillance, and other operational compliance issues.

Prior to joining Patomak, she spent twelve years in the CFTC’s Market Participants Division (MPD), most recently serving as Deputy Director of its Registration and Compliance branch. In this role, she led a team of attorneys responsible for regulatory policy and compliance oversight of swap dealers, major swap participants, futures commission merchants, introducing brokers, commodity pool operators, commodity trading advisors, and retail foreign exchange dealers. Ms. Geraghty directed MPD’s swap dealer oversight program, coordinated interagency initiatives with the Securities and Exchange Commission, Treasury, and Federal Reserve, and served as the principal liaison to the National Futures Association on swap dealer registration and examination matters. She regularly led multiple rulemaking initiatives, as well as the drafting of no-action letters, staff advisories, and interpretative guidance. Ms. Geraghty’s tenure at the CFTC was also marked by deep engagement with enforcement matters, including jointly leading a multi-year bank monitorship with the CFTC’s Division of Enforcement and regularly advising on enforcement actions and settlements.

Prior to joining the CFTC in 2013, she was a compliance officer for Prudential Financial’s global investment management business (now PGIM Private Capital), where she provided compliance support for its private capital and real estate investment divisions. In that role, she advised senior management on legal and regulatory matters under U.S. securities laws, maintained investment adviser and broker-dealer compliance procedures, and conducted forensic testing and risk reviews. She also collaborated with business, legal, and risk functions on contract negotiations, product structuring, and compliance technology solutions. Ms. Geraghty began her legal career as an enforcement attorney for the New Jersey Bureau of Securities, where she investigated complex securities fraud cases and collaborated with state and federal agencies on joint actions and criminal prosecutions.

Ms. Geraghty received her B.A. in economics from the Catholic University of America and her J.D. from the Catholic University of America Columbus School of Law.