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Chiara Bolter

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Chiara Bolter is an associate in Baker McKenzie’s Zurich office and a member of the Firm's Dispute Resolution Practice Group.
Chiara graduated from the University of St. Gallen (HSG) in 2022 with a master's degree in law. Subsequently, Chiara worked as a trainee lawyer for Baker McKenzie Zurich and as a law clerk at the District Court of St. Gallen. Chiara was admitted to the Swiss bar in 2025 and rejoined the Firm in the same year.
In AML & Financial Services Regulatory

United States: No Action, Big Impact – CFTC Harmonizes Cross-Border Rules

by , and 4 Mins Read

On 9 December 2025, the U.S. Commodity Futures Trading Commission (CFTC) issued No-Action Letter 25-42 to streamline compliance for cross-border swap transactions.
The letter aligns with the 2020 Cross-Border Rule by standardizing key definitions such as “U.S. person” and “guarantee,” removes the need for conduit affiliate analysis, and allows continued reliance on prior classifications beyond the original 2027 sunset date. It also supersedes older no-action letters, reducing regulatory inconsistencies and simplifying compliance processes for market participants.