News & Analysis as of

Foreign Entities Commodities Futures Trading Commission

Akin Gump Strauss Hauer & Feld LLP

The Corporate Transparency Act’s Impact on Private Fund Managers: Immediate Planning Needed

Starting on January 1, 2024, entities that are organized in the United States or are registered to do business in the United States will generally be required to disclose to the Financial Crimes Enforcement Network (an...more

Foley & Lardner LLP

CFTC Registration Relief for Non-U.S. CPOs

Foley & Lardner LLP on

On October 15, 2020, the CFTC unanimously adopted amendments to Rule 3.10(c) that will be of assistance to foreign-located persons acting as commodity pool operators on behalf of offshore commodity pools. Rule 3.10(c) will...more

Cadwalader, Wickersham & Taft LLP

Swap Execution Facilities, the Sequel

The Commodity Futures Trading Commission (the “CFTC”) issued a release (the “SEF Proposing Release”) that would make significant revisions to the regulatory requirements that apply under Part 37 of the CFTC Rules (the...more

Dechert LLP

CFTC Staff Issues No-Action Relief Helpful for Non-U.S. Commodity Pool Operators and Commodity Trading Advisors

Dechert LLP on

The U.S. Commodity Futures Trading Commission (CFTC) Division of Swap Dealer and Intermediary Oversight (DSIO) provided no-action relief on February 12, 2016 to commodity pool operators (CPOs) and commodity trading advisors...more

WilmerHale

SEC Adopts Rules on Non-US Firms That “Arrange, Negotiate, or Execute” Security-Based Swaps in the US

WilmerHale on

On Wednesday, the Securities and Exchange Commission (SEC) adopted rules that will affect firms operating in the global security-based swap market. Specifically, the SEC is requiring non-US firms that arrange, negotiate, or...more

Katten Muchin Rosenman LLP

CFTC Extends Swap Data Reporting Relief to Certain Non-US SDs and MSPs

The Division of Market Oversight of the Commodity Futures Trading Commission has extended relief from swap data reporting obligations for swap dealers (SDs) and major swap participants (MSPs) that are non-US persons...more

Katten Muchin Rosenman LLP

CFTC Staff Issues No-Action Relief From Certain Financial Reporting Requirements Applicable to Introducing Brokers

On January 23, the Commodity Futures Trading Commission’s Division of Swap Dealer and Intermediary Oversight (DSIO) issued a no-action letter regarding financial reporting requirements as they apply to foreign introducing...more

Katten Muchin Rosenman LLP

CFTC Extends Relief to Four Foreign Clearing Organizations

On December 18, the Division of Clearing and Risk (DCR) of the Commodity Futures Trading Commission extended the no-action relief previously granted to four foreign clearing organizations: ASX Clear (Futures) Pty Limited,...more

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