Although the pending reforms to the European Market Infrastructure Regulation (EMIR), commonly referred to as EMIR REFIT, have not yet gone into effect, US and other non-EU managers of non-EU alternative investment funds (AIFs) should start determining now whether they will be affected, and, if so, commence preparations for compliance. Any non-EU AIF that is currently classified as a third-country non-financial counterparty (NFC) that is below the applicable EMIR clearing thresholds (NFC-) is likely to be affected.

For more information, see Katten’s advisory, “EMIR REFIT: What Non-EU Asset Managers Should be Doing Now.”