The CFTC released enforcement materiality guidelines for CFTC-registered non-US swap dealers relying on substituted compliance with their home country’s rules in place of CFTC obligations. The CFTC also released a letter clarifying the application of the CFTC’s “US Person” and other cross-border definitions to a proprietary trading firm organized in a non-US jurisdiction with certain US dealings.
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CFTC Issues Letters on Non-US Substituted Compliance Enforcement and Cross-Border Definitions
