CFTC Grants Substituted Swaps Compliance for Six Foreign Jurisdictions

Skadden, Arps, Slate, Meagher & Flom LLP

Mark D. Young Maureen A. Donley Theodore M. Kneller

The CFTC recently approved substituted compliance determinations for six foreign jurisdictions covering swap regulatory requirements of the Dodd-Frank Act. However, this approach – which builds on the CFTC's policy of recognizing comparable overseas regulatory regimes – has resulted in a complicated mosaic of compliance obligations.

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