Lead, FCM Legal

Job description

ABOUT POLYMARKET Polymarket is the world's largest prediction market platform. We enable individuals to express views on real-world events by trading on outcomes across politics, economics, sports, culture, and current affairs. Built as a peer-to-peer marketplace with no centralized "house," Polymarket aggregates diverse opinions into transparent, market-based probabilities that reflect collective expectations about the future. We're growing fast — both in terms of volume ($21B traded in 2025) and adoption as an alternative news source. Our ambition is to become a ubiquitous beacon of truth in global media and we need your help adding fuel to the fire. ABOUT THE ROLE Polymarket operates a CFTC-regulated designated contract market (DCM) and derivatives clearing organization (DCO). As we scale, the legal and regulatory infrastructure supporting our FCM relationships has to keep pace with the business. This role exists to own that work directly — not manage it from a distance. You'll sit inside a small, senior legal team and work closely with Compliance, Surveillance, and product. The mandate is clear: keep the FCM function legally sound, anticipate regulatory risk before it becomes a problem, and engage with the CFTC and NFA from a position of deep technical fluency. We need someone who knows FCM regulation cold, can move quickly, and will be consulted early and often by the business — not looped in at the end to sign off. WHAT YOU'LL DO - Advise product and business teams on CFTC implications before new features ship, not after - Draft and negotiate customer-facing FCM agreements, disclosures, and related documentation to ensure they are accurate, compliant, and ready to send - Prepare responses to CFTC and NFA regulatory inquiries and examinations, coordinating across Legal and Compliance to produce tight, well-supported submissions - Draft comment letters, no-action requests, and interpretive submissions on matters affecting the FCM, DCM, and DCO - Track CFTC enforcement actions, rulemaking, and NFA notices to surface emerging risks and translate them into actionable guidance for internal teams - Advise on FCM policies and procedures covering segregation, net capital, margin, and customer protection requirements - Support litigation strategy on matters touching FCM operations and exchange regulation WHAT WE'RE LOOKING FOR - J.D. and active U.S. bar membership - 3–7 years of FCM-focused legal or compliance experience, either in private practice, at a regulator, or in-house at a derivatives firm - Deep working knowledge of the Commodity Exchange Act, CFTC regulations, and NFA rules, particularly as they apply to FCMs — including segregation, net capital, and margin requirements - Demonstrated ability to write clearly and persuasively — comment letters, no-action requests, and customer agreements that are filed or sent with minimal revision - A track record of being brought into business and product decisions early, not used as a last-minute legal check - Strong judgment about when to escalate, when to move, and how to give practical guidance under regulatory uncertainty - Direct experience with CFTC examination or enforcement processes - (Plus) Familiarity with prediction markets or event contracts - (Plus) Interest in emerging financial technologies and market structure BENEFITS - Competitive salary & equity - Unlimited PTO - Full Health, Vision, & Dental coverage - 401k match - Hardware setup: new MacBook Pro, big display, & accessories