Cross-border stricter-rule-applies approach causing confusion

Global regulators have agreed to cooperate when implementing new derivatives rules on a cross-border basis, but market participants are unsure as to how this will work in practice

Market participants are struggling to work out how a new global agreement on the cross-border implementation of new derivatives regulations will work in practice, with a principle that the stricter rule should apply proving particularly problematic.

The agreement, published on August 30, represents the views of regulators in Australia, Brazil, the European Union, Hong Kong, Japan, Ontario, Quebec, Singapore, Switzerland and the US, and follows a similar understanding between the European