US person problems: Hedge funds caught in transatlantic tug-of-war

Identity crisis

Allan Yip, Simmons & Simmons

The laws of quantum mechanics, which state an object can exist in multiple forms and places at the same time, confused even Einstein, who said, “no reasonable definition of reality could be expected to permit this”.

Hedge funds could say the same thing about rules governing cross-border derivatives transactions, which in their current form will require some firms to do the impossible.

“The cross-border application of US regulation puts a lot of European hedge funds in the impossible position of