“And then the CFTC came out with new guidance that said no, even if the trade is booked offshore, if employees involved in related sales or trading activities are sitting in the U.S., then the bank is subject to full compliance.”
“And then the CFTC came out with new guidance that said no, even if the trade is booked offshore, if employees involved in related sales or trading activities are sitting in the U.S., then the bank is subject to full compliance.”
—Jeff Robins, partner at Cadwalader, Wickersham & Taft in New York, on recent guidance released by the U.S. Commodity Futures Trading Commission that expands the scope of the regulator’s crossborder reach. The guidance specifies that employees from non-U.S. firms based in the U.S. must comply with Dodd Frank, even if they are processing non-U.S. swaps.
