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Swap Dealers Cross-Border Transactions Regulatory Requirements

Swap Dealers are individuals or entities who "hold themselves out as dealers in swaps, make markets in swaps, regularly enter into swaps with counterparties as an ordinary course of business for its own... more +
Swap Dealers are individuals or entities who "hold themselves out as dealers in swaps, make markets in swaps, regularly enter into swaps with counterparties as an ordinary course of business for its own account, or engage in any activity causing the individual or entity to be come commonly known in the trade as a dealer or market maker of swaps." Swap Dealers are defined under the Commodity and Exchange Act and must register as such under the Commodity Futures Trading Commission's Final Rules.  less -
McDermott Will & Schulte

CFTC Staff Letter 25-14: What Is a “U.S. Person”?

On May 21, 2025, the Commodity Futures Trading Commission’s (CFTC) Market Participants Division and Division of Market Oversight jointly issued Staff Letter 25-14 in response to a request from SCB Limited, a Bahamas-based...more

Hogan Lovells

Final rule: The CFTC clarifies the extraterritorial application of cross-border derivatives regulation – implications for the buy...

Hogan Lovells on

On 14 September 2020, the Commodity Futures Trading Commission (CFTC) published a final rule in the Federal Register entitled "Cross Border Application of the Registration Thresholds and Certain Requirements Applicable to...more

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