Anne M. Termine > Bracewell LLP > Washington DC, United States > Lawyer Profile

Bracewell LLP
2001 M STREET, NW, SUITE 900
United States


Drawing on nearly 20 years of CFTC experience, Anne Termine represents stakeholders in the commodities, derivatives and cryptocurrency markets in connection with internal investigations, regulatory enforcement and litigation matters. She also helps clients with regulatory advocacy before various agencies and in developing practical compliance and other policies and procedures tailored to their individual business needs.

From October 2003 to August 2016, Anne was a chief trial attorney in the US Commodity Futures Trading Commission’s (CFTC) Division of Enforcement, where she investigated and prosecuted alleged violations of federal laws related to commodities, futures, options, swaps and other derivatives. She led investigations involving the attempted manipulation and false reporting of natural gas and crude oil prices, multi-million dollar Ponzi and other fraud schemes, and the illegal operations of event-based or prediction markets. Anne notably was the architect and manager of the landmark CFTC enforcement program involving the manipulation and false reporting of LIBOR, Euribor and TIBOR. She led negotiations with nine global financial institutions, imposing $2.8 billion penalties in the sprawling international investigation that involved regulatory and law enforcement agencies across Europe and Asia, multiple divisions of the US Department of Justice, and a coalition of more than 40 state attorneys general. In recognition of her leadership handling the LIBOR investigations, she received the Chairman’s Award for Excellence, the CFTC’s highest award.


Tulane University Law School,
J.D., 1999, magna cum laude, Order of the Coif
Bucknell University,
B.A., 1993

Lawyer Rankings

United States > Dispute resolution > Corporate investigations and white-collar criminal defense

Bracewell LLP fields a team of deeply experienced practitioners under the leadership of Washington DC’s Stephen Braga. It is well versed in government investigations and caters to both corporate and individual clients. Key areas of focus for the practice include enforcement actions, compliance, monitorships, fraud and antitrust issues. Braga has considerable experience in defending clients in criminal and civil matters before trial and appellate courts. Seth DuCharme joined in New York from the DOJ in May 2021, and Anne M. Termine joined in Washington DC from Covington & Burling LLP in June 2021. Paul Shechtman left the firm in May 2022.

United States > Industry focus > Energy regulation: conventional power

Bracewell LLP has a particularly strong FERC practice and also represents clients before federal appellate and district courts. The group has significant FERC litigation experience, handling multi-party contested proceedings concerning issues such as market design and transmission, and Return-on-Equity disputes, as well as day-to-day counselling. The team works closely with its Policy Resolution group to advise on major renewable energy infrastructure projects, such as offshore wind and electricity transmission. Catherine McCarthy  heads the practice and handles the full range of issues, including centralized markets. The arrival of Rachael Marsh from the FERC in July 2021 has further bolstered the group’s offering, and comes in addition to the arrivals of Anne M. Termine and Theodore Duver from Covington & Burling LLP and Loeb, Block & Partners LLP, respectively. Michael Brooks  and Stephen Hug are also recommended. All lawyers are based in Washington DC, apart from Duver who is based in New York.

United States > Industry focus > Energy regulation: oil and gas

Bracewell LLP represents oil and gas pipeline and storage companies in contested proceedings at FERC and has ‘rare’ and ‘true regulatory experience in liquids Beyond FERC, the team represents clients in federal and appellate courts as well as in dual-track civil litigation and government investigations, with the June-2021 arrival of Anne M. Termine from Covington & Burling LLP strengthening the group’s offering in this area. Managing partner of the Washington DC office, Mark Lewis focuses on midstream commercial and regulatory matters, advising on the development of significant projects and day-to-day operations. Michael Brooks‘ practice, in turn, centres on CFTC work. The team has seen continued growth, most recently the July-2021 hire of former FERC attorney Rachael Marsh. All lawyers are based in Washington DC.