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Financial Services Industry › Cross-Border Transactions › New Guidance

Jones Day

CFTC Issues Advisory to Clarify FBOT Registration Framework for Non-U.S. Crypto Exchanges to Access U.S.-based Participants

Jones Day on

To promote regulatory clarity, on August 28, 2025, the Commodity Futures Trading Commission ("CFTC")'s Division of Market Oversight issued an advisory to reaffirm its longstanding foreign board of trade ("FBOT") registration...more

Jones Day

CFTC Divisions Interpret "U.S. Person" Definition and U.S. Location Versus Foreign Location

Jones Day on

A 2024 CFTC enforcement action settlement that may have introduced a new test for when the Commodity Exchange Act and the agency's regulations apply on a cross-border basis concerned then-CFTC Commissioner and now Acting CFTC...more

Morgan Lewis

The Commodity Futures Trading Commission's Swaps Cross-border Guidance Proposal

Morgan Lewis on

The Dodd-Frank Act amended the Commodity Exchange Act (the Act) to create a new regulatory framework for swaps, and added Section 2(i) to require the application of the Dodd-Frank Act swap requirements to activities that...more

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