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Cross-Border Transactions New Guidance Commodities Futures Trading Commission

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

Alston & Bird

CFTC Guidance Clarifies Non-U.S. Person Status of Certain Offshore Trading Firms

Alston & Bird on

Our Investment Funds Team examines an interpretive letter from the Commodity Futures Trading Commission (CFTC) that may help to clarify when non-U.S. firms with U.S. contacts can be considered non-U.S. persons for...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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