CFTC Closes Cross-border Swaps Compliance Loophole | Practical Law
The CFTC's Division of Swap Dealer and Intermediary Oversight issued a staff advisory clarifying that swaps arranged, negotiated or executed by persons in the US must comply with CFTC transaction-level requirements if one of the parties to the swap is a swap dealer registered with the CFTC, regardless of the jurisdiction of organization or location of the counterparty.