Compliance with the Final Guidance on the cross-border application of the swaps provisions of the Dodd-Frank Act recently took effect.1 The Final Guidance, issued in July 2013 by the Commodity Futures Trading Commission ("CFTC" or the "Commission"), applies to persons who conduct crossborder swaps transactions with any jurisdictional nexus to the United States, regardless of whether they are required to register with the CFTC in any capacity.
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Originally published in the May 2014 edition of Futures & Derivatives Law Report, Vol. 34, Issue 5.
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