On February 12, the U.S. Commodity Futures Trading Commission’s Division of Swap Dealer and Intermediary Oversight provided “no-action relief from registration” to a specific subset of individuals: “persons located outside the United States who act as Introducing Brokers, Commodity Trading Advisors, or Commodity Pool Operators in connection with swaps that are not subject to a CFTC clearing requirement on behalf of persons located outside of the United States.”  Release.