Risk on extraterritoriality

Asia globe

The Commodity Futures Trading Commission (CFTC) published its long-awaited cross-border guidance on July 12 – a year after it released its initial guidance.

The guidance outlines how the Dodd-Frank Act applies across borders, and sets out the definition of US person, as well as the treatment for non-US swap dealers, non-US swap participants and foreign branches of US banks.

Central to the guidance is the concept of substituted compliance, which allows non-US swap entities to apply foreign rules

To continue reading...

You need to sign in to use this feature. If you don’t have a Risk.net account, please register for a trial.

Sign in
You are currently on corporate access.

To use this feature you will need an individual account. If you have one already please sign in.

Sign in.

Alternatively you can request an individual account here: