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On October 1, 2018 Commodity Futures Trading Commission (CFTC) Chair J. Christopher Giancarlo released a white paper recommending potential reforms to the agency's approach to the extraterritorial, or cross-border, application of its swaps trading rules. The proposed reforms take into account criticism of the CFTC's current approach to the cross-border application of its rules, as well as regulatory developments in other jurisdictions. According to Giancarlo, the reforms are intended to create a territorial, risk-based approach that relies on greater deference to regulators in jurisdictions with comparable regulatory frameworks (comparable jurisdictions), where appropriate. The white paper makes general proposals in several areas, including registration requirements for non-US central counterparties (CCPs), trading venues and swap dealers, clearing and trade execution requirements and transactions between non-US persons that are arranged, negotiated or executed within the United States (ANE transactions).