The CFTC has proposed long‑awaited interpretive guidance concerning the extent to which the new registration and regulatory requirements for swaps under the Dodd‑Frank Act apply to transactions and persons outside of the United States. Since the Dodd-Frank Act was introduced, its perceived extraterritoriality has been one of the major talking points and controversies. The interpretive guidance, if adopted, would address certain key concerns raised by market participants since the enactment of the Dodd‑Frank Act, particularly in the context of swap dealer and major swap participant registration.View full memo, "Cross-Border Application of the Swaps Provisions of the Dodd-Frank Act"
