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23 March 2016
On January 4 2016 the Commodity Futures Trading Commission (CFTC) proposed a rule offering an alternative to the requirement for foreign natural persons to provide fingerprints when applying for CFTC registration.
The proposal provides that any such person's registered firm may complete a criminal history background check instead of submitting fingerprints. The proposal generally codifies CFTC Staff Letters 12-49 and 13-29 and would supersede those letters, if adopted. Comments on the proposed rule were due by February 11 2016.
The CFTC press release is available at www.cftc.gov/PressRoom/PressReleases/pr7302-16 and the proposed rule is available at www.cftc.gov/idc/groups/public/@newsroom/documents/file/federalregister010416.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 (firstname.lastname@example.org, email@example.com or firstname.lastname@example.org). The Shearman & Sterling website can be accessed at www.shearman.com.
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