UNITED STATES: CFTC Releases Procedures on Registered Non-U.S. Swap Entities

Wednesday May 21 2025

On 20^th May 2025, the Commodity Futures Trading Commission’s (CFTC) Market Participants Division (MPD) and Division of Enforcement (DOE) released procedures regarding CFTC-registered non-U.S. swap dealers or major swap participants (Swap Entities) relying on substituted compliance.

The procedures establish how the Divisions will address potential non-compliance with foreign law that has been found by the CFTC to be comparable in outcome to the Commodity Exchange Act or CFTC regulations pursuant to a substituted compliance order.

The procedures were developed following a request, submitted jointly by Institute of International Bankers (IIB), International Swaps and Derivatives Association (ISDA), and Securities Industry and Financial Markets Association (SIFMA), for guidance regarding the CFTC’s referral process for substituted compliance.

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