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.