Andrea Maharam Corcoran
Andrea Maharam Corcoran

Andrea Maharam Corcoran

Founder and Principal Align International, LLC

Andrea Maharam Corcoran, Principal of ALIGN, advises the C-suite of firms and regulatory authorities located on five continents on various regulatory and policy puzzles. Her consulting services include: confidential evaluation of organizational structures and processes, development of regulatory and compliance strategies, training, adaptation to international standards, failure analyses, second opinions and so-called“ autopsy” reports for various clients.

Andrea Maharam Corcoran

Founder and Principal Align International, LLC

Founder's Profile

Ms. Corcoran initiated her customized consultancy services in 2008 following a long career in the public sector. She served nationally as the director of two Divisions of the US Commodity Futures Trading Commission (CFTC): initially Trading and Markets, the CFTC’s then-principal regulatory arm, and, subsequently, the newly created, Office of International Affairs. Internationally, she chaired two IOSCO (International Organization of Securities Commissions) working groups: the committee that authored Principles for the Oversight of Screen Based Trading Systems in Derivatives Products, and the Task Force on Implementation of the Objectives and Principles of Securities Regulation (Principles). The Task Force created the first methodology for assessing compliance with the IOSCO Principles and was the first IOSCO committee to admit both mature and growth market jurisdictions. The Assessment Methodology (originally completed in 2003) became a basis for reports on standards and codes under the World Bank/IMF FSAP (Financial Sector Assessment Program), endorsed by the G20 Pittsburgh Summit Leaders Statement in response to the Great Financial Crisis (GFC) of 2008. The Methodology and a related e-methodology were updated in 2011, 2013, and 2017.

At the CFTC, Ms. Corcoran was a critical member of the policy and supervisory team that spearheaded several initiatives. She was the architect of Part 190-special bankruptcy rules for listed derivatives, anticipated by substantial amendments to the Bankruptcy Code in 1978 through 1982 and now Section 24 of the Commodity Exchange Act which provides the CFTC with rulemaking authority under that Code. These rules, recently reinforced and extended in 2021, implement the law intended to protect the markets from contagion and systemic risk, strengthen incentives for strong risk management practices and facilitate prompt transfer of positions and funds permitting market participants to maintain hedges, fostering market stability and mitigating disruption and costs.

​She also conceived provisions for transaction of cross-border business, which enhanced US-based customer access to foreign products and non-US based customer access to US products. The rules, known as Part 30, adopted a home/host methodology (similar to classic conflicts of law and the original European Union Lamfalussy process). As such, the process took account of the jurisdictions best-placed to oversee a particular type of activity or entity and recognized and gave deference to comparable laws and oversight, subject to certain conditions.

Additionally she:

  • Was CFTC staff representative to the President’s Working Group on Financial Markets, 1987 to 1997.
  • Led team responding to the collapse of Barings bank, the Sumitomo copper market manipulation, and collaborated on responses to physical disruptions at US listed derivatives exchanges due to Chicago River flooding and the 1993 and 2001 NYC World Trade Center attacks.
  • Oversaw production of a report published by the CFTC in 1993, pertaining to over-the-counter products, that identified various risk factors and mitigating measures, including the systemic value of clearing.  Clearing was later recognized in policy responses to the 2008 crisis as a critical factor in financial market resilience. 
  • Advocated rules and processes supporting bulk transfers, customer adherence to exchange rules, “what if” risk analysis, and gross margining of omnibus accounts, all matters relevant to avoidance or mitigation of market failures and to expeditious transfer of customer positions, recovery and resolution of insolvencies and defaults.


LLB (JD) Harvard Law School, Roscoe Pound Award (moot court team), moot court semi-finalist, Harvard Gen AHF teaching fellowship 

BA Stanford University, magna cum laude with Honors in History, Phi Beta Kappa

MIT Sloan School of Management Certificate of Successful Completion of Executive Program re: Blockchain Technologies: Business Innovation and Application


New York (in-active), California, District of Columbia bars; expert roster for World Bank, IMF (through 2017 ); for Align: US Government Contractor registry SAMS (since 2015 )


Council on Foreign Relations

The Washington Institute of Foreign Affairs

Foreign Policy Discussion Group

ABA Derivatives Committee



Presidential Executive Rank Award* (1988, 1996) under Presidents Reagan and Clinton, respectively

FIA Futures Hall of Fame (2013)

Women of Outstanding Achievement in International Financial Education, June 17, 2016, UN Headquarters New York via the Honourable Anna Chennault

*Highest monetary award for senior executive service


  • Expert advisor/short term contractor, to multiple clients, including International Financial Institutions (IMF/WB), Financial Services Volunteer Corps (FSVC), Toronto Centre on Global Leadership in Financial Supervision (TC), Luxembourg Development Corporation (LuxDev) and Vietnam State Securities Commision (SSC), and to various other financial regulatory authorities and clients.
  • US observer on the Market Participants Consultative Panel of the Committee of European Securities Regulators (CESR) prior to its succession in 2011 by the European Securities Markets Authority (ESMA).
  • Chairman of the Securities Advisory Board of the Toronto Centre and ex officio member of the TC Board, through May 2017.
  • Public Director and Head of the Regulatory Oversight Committee of the New York Stock Exchange affiliate, NYSE-Liffe US prior to NYSE's merger with ICE.
  • Public Director of National Futures Association (NFA).
  • Expert witness in several financial cases involving bankruptcy, segregation practices, and international standards.
  • Decade-long adjunct Professor at Georgetown Law Center in listed derivatives law, preparing the first electronic syllabus.
  • Centre for International Legal Studies, teacher on American legal system and financial regulatory oversight.
  • Participation on multiple panels internationally and domestically.


Legal writing, including briefs and analyses.

Development of case studies, syllabi, and teaching modules.

Crisis management scenarios, policy design and consensus building.

Conduct of Financial Stability Assessments for the securities (including derivatives) sector. (Finland, Singapore, France, Morocco (update), Indonesia, Russia, Argentina, Colombia, Vietnam, Republic of Korea, Kazakhstan and multiple peer reviews, including France, Kenya, Spain, Mexico, Albania, Brazil, and Japan.) Peer review of financial market technical assistance for Morocco and Saudi Arabia. FSAP self-assessment and prep.

Advice on aspects of listed derivatives markets’ development (including derivatives on physical commodities) legislation, regulation and oversight [China Securities Regulatory Commission (CSRC), Egypt, India, Ukraine; clearing and settlement (Jordan)]; risk management for regulators, market users and intermediaries; insolvency and customer funds protection regimes; conduct of business regulation; training, including crisis management, for regulators with respect to regulatory policy and strategies for oversight of financial markets.

Design of securities component of risk-basing models and articulation of differences between prudential and market-based approaches based on experience in multiple jurisdictions

Development of intervention and policy responses to acute market situations, such as the 1987 Market Crash, the collapse of Barings, plc and the Sumitomo copper manipulation.

Design of cross-border operational and supervisory agreements, such as the multi-lateral Boca Declaration, a warehouse stocks information sharing agreement with the UK, cross-border exchange  access; and arrangements for cross-border broker license recognition based on comparability, substituted compliance and deference.

Infrastructure surveillance and oversight programs.

Language Skills: English, French, Spanish


  • The short silver report on exchange responses to the Hunt silver manipulation.
  • The post Barings collapse Windsor Accord, promoting means to secure segregation across borders, initially adhered to in London by multiple jurisdictions.
  • The Tokyo and London Communiqués, in response to the Sumitomo manipulation outlining specific information to be exchanged for surveillance of stressed markets.
  • The Boca Declaration, then the first multi-lateral surveillance information sharing arrangement among securities authorities in multiple jurisdictions and the related exchange arrangement, pertaining to related listed derivatives risks, the signature of which was a condition of access to certain markets, and
  • Many other international dialogues and risk-reducing initiatives.


Gas-lighting” Ourselves—A Cinematic Retrospective, Version 2.0 (2019)

Cooperative Arrangements Among Capital Markets(2008)

Keeping The Market Open: Lessons From 1987(1997)

The link between “extra-territorial” manipulation enforcement for domestic financial products linked to foreign markets and US currency as a reserve currency(2020)

Amicus Brief

In the News

New York Times Energy Pricing, a continuing issue (1991)

Videos & Podcasts

Listen to Andrea Corcoran’s IPO-Vid interview (#119) with well-known financial talk show host Patrick Young on the reasons behind creation of the US CFTC, the reasons for differences between the focus of futures and securities market regulation, and how the techies should not forget the humans in designing the markets of the future.

Patrick Young IPO-VID Episode #119 interview with Andrea Corcoran