Alexander S. Holtan

Alexander Holtan headshot


Alexander "Alex" Holtan is an attorney in Holland & Knight's Washington, D.C., office. Mr. Holtan counsels energy clients on trading in derivatives, enforcement matters and compliance with derivatives-related regulatory requirements, including those imposed by the Commodity Futures Trading Commission (CFTC). He provides interpretation and guidance on rules promulgated by various federal agencies, the National Futures Association (NFA) and a number of derivatives exchanges.

In addition, Mr. Holtan frequently assists clients, including swap dealers, commodity trading advisers, commodity pool operators, introducing brokers and commodity traders with CFTC and NFA registration, and creating and improving derivatives trading compliance programs.

Mr. Holtan also has helped clients launch commodity trading and investment funds for crude oil and renewable energy and carbon offsets and allowances. He also advises energy firms, commercial end users, investment banks and pooled investment vehicles on an array of derivatives and other transactions.

Using his knowledge and experience with analogous derivatives regulatory matters in the U.S., Mr. Holtan advises on derivatives regulatory developments in Canada (federal and provincial), including issues related to reporting, margin, clearing and exemptions from dealer registration.

As a registered lobbyist, Mr. Holtan lobbies Congress on topics that include derivatives regulation, bankruptcy and matters involving aspects of financial regulation. He also works with clients to develop advocacy strategies and provides guidance on the Lobbying Disclosure Act (LDA) and Foreign Agents Registration Act (FARA). In this respect, Mr. Holtan provides counsel to clients and helps structure and implement compliance programs.

Prior to joining Holland & Knight, Mr. Holtan was a partner at a global law firm in its Washington, D.C., office. His previous experience also includes serving as a law clerk for the U.S. Senate Committee on Banking, Housing and Urban Affairs, and as the Washington, D.C., programs director for the Democratic Congressional Campaign Committee.

Representative Experience

  • Advise a registered swap dealer on restructuring of swap dealing business
  • Advise multinational energy and commodities trading companies on evaluating and improving trading compliance programs
  • Advise clients on registration as commodity trading advisors, commodity pool advisors and introducing brokers
  • Advocate for multiple trade associations before the Commodity Futures Trading Commission (CFTC), U.S. Congress, Canadian securities regulators and international regulatory bodies
  • Advise investment funds on compliance with California Air Resources Board obligations

  • Represent a registered commodity trading advisor and introducing broker in connection with alleged fraud and disclosure failures
  • Represent multiple clients in connection with alleged failure to register as swap execution facilities
  • Represent an energy marketer in connection with alleged failure to register as a futures commission merchant
  • Represent a fuel marketing company in relation to state-level gasoline market manipulation investigation
  • Represent clients before the National Futures Association (NFA), CME Group and Intercontinental Exchange

  • Assist clients with negotiation of energy trading documentation, including International Swaps and Derivatives Association (ISDA) Master Agreements, Edison Electric Institute (EEI) Master Agreement and cleared derivatives documentation
  • Assist a client with the negotiation of investment management agreements


  • University of Virginia School of Law, J.D.
  • University of Virginia Darden School of Business, MBA
  • Georgetown University, B.A.
Bar Admissions/Licenses
  • District of Columbia
  • Legal Counsel for the Elderly, Board Advisory Committee
Honors & Awards
  • Chambers Global – The World's Leading Lawyers for Business guide, Capital Markets: Derivatives, 2022, Capital Markets: Derivatives (Up & Coming), 2024
  • Chambers USA – America's Leading Business Lawyers guide, Capital Markets: Derivatives, 2021, 2022; Derivatives (Up & Coming), 2023
  • The Legal 500 USA, Structured Finance: Derivatives and Structured Products, 2021, 2022
  • Rising Star, Washington, D.C., Super Lawyers magazine, 2014-2020
  • National Futures Association (NFA), Swaps Proficiency Requirements, Certified, Long Track, 2020


Speaking Engagements