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Cross-Border Transactions Registration Requirement Commodities Futures Trading Commission

McDermott Will & Emery

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

A&O Shearman

SEC Proposes Modifications to Cross-Border Application of Security-Based Swaps Regime

A&O Shearman on

The Securities and Exchange Commission (SEC) continues to take steps toward implementation of its security-based swap (SBS) dealer registration framework. A particular area of concern for market participants has been how the...more

Skadden, Arps, Slate, Meagher & Flom LLP

"CFTC Proposes Rules to Count Cross-Border Swaps for Swap-Dealer Thresholds and Other Requirements"

The CFTC’s newly proposed rules on cross-border transactions address which swap activities affect swap-dealer thresholds and trigger transaction-level swap requirements. These are the latest in a series of CFTC rulemakings,...more

Morrison & Foerster LLP

SEC Adopts Rule Amendments Addressing Dealing Transactions Between Non-U.S. Persons that are “Arranged, Negotiated, or Executed”...

On February 10, 2016, the U.S. Securities and Exchange Commission (“SEC”) approved final rule amendments to its cross border rules that address how the security-based swap dealer definition applies to security-based swap...more

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