Financial Institutions Advisory & Financial Regulatory counsel Donald Lamson (Washington, DC) was quoted in The Financial Times on the potential impact of the Dodd-Frank Act's Volcker Rule on non-United States-based financial institutions in a story titled, "Banks Outside US Face Prop Trading Ban."

Considering aspects of the Volcker Rule rumored to be included in a soon-to-be-released new draft, Lamson noted, "If the trade settles in New York that would be a US trade and that could be prop trading." He continued by explaining, "If you have a foreign branch and a US branch employee talks to someone at headquarters about a trade even then that trade could all of a sudden be part of the prop trading prohibition. In a global market, when it's very difficult to impose walls, the scope of this exemption could be narrower than expected.