On March 28 2016 the US Commodity Futures Trading Commission (CFTC) approved a final rule that would allow a foreign natural person applying for CFTC registration to complete and submit a criminal history background check as an alternative to submitting fingerprints (for further details please see "CFTC approves proposed rule offering alternative to fingerprinting").
The rule codifies and supersedes the no-action relief previously given in CFTC Staff Letters 12-49 and 13-29. The rule will become effective 30 days after publication in the Federal Register.
The full text of the CFTC rule is available at: www.cftc.gov/idc/groups/public/@newsroom/documents/file/federalregister032816.pdf.
For further information on this topic please contact Donna M Parisi, Geoffrey B Goldman or Azam H Aziz at Shearman & Sterling LLP by telephone (+1 212 848 4000) or email ([email protected], [email protected] or [email protected]). The Shearman & Sterling website can be accessed at www.shearman.com.
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