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In November 2020, the CFTC published two no-action letters extending previously granted no-action relief related to Brexit. The relief was intended to provide “greater certainty to the global marketplace” in connection with Brexit. The no-action letters, as discussed below, primarily address requirements applicable to swap dealers, but nevertheless may assuage concerns by end-users and other market participants over potential Brexit-related disruptions.
The UK left the EU on January 31, 2020 and entered into a transition period set to expire on December 31, 2020. (Notably, to prepare for the expiration of the transition period, the UK government passed the European Union (Withdrawal) Act 2018, which, upon the expiration of the transition period, will “transpose” certain EU law and regulations into UK law and regulations, and grant authority vested in certain EU institutions to the Financial Conduct Authority and c