The Volcker Rule imposes significant restrictions on “proprietary trading” by banking organizations and their affiliates. The purpose of this Memorandum is to discuss how these restrictions may impact broker-dealer affiliates of foreign banking organizations that conduct business in the United States or with U.S. customers.

Overview of the Restrictions on Proprietary Trading -

The Volcker Rule applies to all banking entities, which are defined to include foreign banking organizations that have U.S. branches or agencies or which own U.S. banks or certain other U.S. subsidiaries (“FBOs”). Also covered by the Rule are affiliates of FBOs, including affiliated broker-dealers located in the United States or overseas.