Paul Dengel understands the stakes when financial regulators claim a client has violated the rules. Enforcement proceedings can threaten the client’s viability, and potentially ruinous damages claims inevitably accompany high-profile governmental proceedings. Paul knows that clients facing these threats need solutions that are carefully orchestrated and aggressively implemented. The right strategy may mean fighting all the way to trial or creating the leverage for a sensible settlement.  

Paul’s focus is on derivatives markets and complicated trading strategies involving those markets. He built this knowledge representing the Cboe for more than 25 years. Today, Paul continues to lead all aspects of the firm’s litigation and regulatory counseling for Cboe. This deep foundation in the options markets equips Paul to handle disputes and compliance challenges about the most complicated derivatives trading strategies. One recent example involved defending a trading firm from regulatory and civil claims that the firm’s complex derivatives trading strategy amounted to market manipulation. Paul identified and communicated a legitimate economic rationale for this complicated trading strategy, paving the way for a successful resolution of these potentially disastrous attacks.    

Beyond successfully fighting off regulatory charges when they come, Paul is adept at helping firms avoid regulatory problems. He understands and speaks the language of both the regulator and the regulated, having worked both for trading firms and for exchanges like Cboe. This special perspective enables him to be particularly effective as both litigator and counselor in matters involving the financial markets.

  • Experience

    • Two securities exchanges hired Paul to lead their defense against nationwide class actions. The plaintiffs claimed that the exchanges engaged in wrongdoing in connection with high-frequency trading that allegedly harmed all buyers and sellers of stock over a five-year period.
    • Paul successfully resolved Commodity Futures Trading Commission (CFTC) regulatory charges against a client after the CFTC alleged the company’s trading strategy manipulated certain energy futures markets. Knowing that there were parallel class actions pending against the company, he negotiated a consent order with the CFTC that contained no findings of fact or legal conclusions. That consent order enabled the client to successfully settle the class actions.
    • A securities exchange turned to Paul for help fighting a Securities and Exchange Commission (SEC) enforcement action alleging failure adequately to enforce certain rules and failure to act pursuant to properly approved rules. With Paul’s help, the matter was successfully settled.
    • Paul was hired by a futures commission merchant when the client was charged in a CFTC reparations case with fraudulent handling and improper liquidation of customer accounts. The case went to trial, and Paul won defense judgments on all counts.
    • When a securities exchange found itself embroiled in a $300 million federal securities fraud class action, it turned to Paul to resolve the matter. The case involved allegations of inadequate disclosure of the risks of unusual market operation during periods of market volatility. Paul obtained partial summary judgment and then successfully settled the remainder of the case.
    • A precious metals seller called on Paul when the CFTC began investigating the seller for alleged violations of new CFTC rules governing financed sales of precious metals. No enforcement charges were brought.
    • Paul also helped brokers under suspicion of late trading and involvement in allegedly improper market timing. Paul intervened, and the SEC declined to bring enforcement charges.
  • Credentials


    • University of Virginia School of Law, J.D., 1979
      Order of the Coif
    • Princeton University, A.B., 1976

    Bar Admissions

    • Illinois
    • U.S. Court of Appeals for the Seventh Circuit
    • U.S. Court of Appeals for the Tenth Circuit
    • U.S. District Court for the Northern District of Illinois (Trial Bar)
    • U.S. District Court for the Eastern District of Wisconsin

        Professional Certifications

        • American Bar Association, Litigation Section
        • Chicago Bar Association
      • Insights

        News Release

        Eighty-Eight Attorneys Named to 2020 Leading Lawyers

        Schiff Hardin LLP is pleased to announce that 88 attorneys have been named to the 2020 Leading Lawyers list.

        News Release

        Schiff Hardin and CVLS Celebrate 40-Year Pro Bono Partnership

        Schiff Hardin LLP and Chicago Volunteer Legal Services (CVLS) are proud to commemorate 40 years of their unique and trailblazing pro bono partnership to advance change, improve lives, and bring justice, which began with the first-ever firm adoption of a CVLS neighborhood legal clinic in 1979.

        Up Close and Personal

        First-Ever Firm Adoption of a CVLS Clinic: Pro Bono Leap Becomes Model for Firms Across Chicago

        Schiff Partner Paul Dengel reflects back on founding the first firm-adopted CVLS neighborhood clinic – from how it all began in the early years to the reason why it remains strong 40 years later.

        News Release

        2019 Leading Lawyers Lists Recognize 95 Schiff Attorneys

        Schiff Hardin LLP is pleased to have 95 attorneys named to the 2019 Leading Lawyers list.

        News Release

        95 Schiff Hardin Lawyers Named to 2018 Leading Lawyers Lists

        Ninety-six Schiff Hardin lawyers have been named to the 2018 Leading Lawyers lists for Illinois and Michigan.

        News Release

        99 Schiff Hardin Attorneys Named to 2017 Leading Lawyers List

        Ninety-nine Schiff Hardin lawyers have been named to the 2017 Leading Lawyers list for Illinois and Michigan.


        Eleventh Circuit Limits SEC Look-Back Period and Sets Up Circuit Split

        Does the general federal statute of limitations apply to government enforcement actions seeking “disgorgement?” The SEC says no.

        News Release

        91 Schiff Hardin Lawyers Named to 2016 Illinois, Michigan Leading Lawyers Network

        The list is comprised of those attorneys who are most recommended as top lawyers among their peers.


        Derivatives & Futures Update

        CFTC Proposes Algorithmic Trading Regulations for Proprietary Traders, FCMs, and Exchanges

        Other Publications

        • Contract Law handbook, Chapters: "Contract Formation under Article 2 of the UCC," and "Problems in Contract Formation," Illinois Institute for Continuing Legal Education (IICLE)
      • Citizenship

        Pro Bono Activities

        Paul is one the firm’s two Pro Bono Partners. In that capacity, he leads the firm’s pro bono efforts. Paul regularly volunteers at a legal clinic that the firm operates and that he helped found 35 years ago. In addition, Paul has handled a series of criminal matters for low income individuals, including three murder cases. In a death penalty case that he took over post-conviction, Paul and his team were able, after more than a decade of work, to exonerate their client and to obtain a full pardon on the ground of actual innocence.