Ananda Radhakrishnan (US)

Photo of Ananda Radhakrishnan (US)

Ananda joined Norton Rose Fulbright's Washington, DC office in 2014 after serving the previous 12 years at the Commodity Futures Trading Commission. Most recently, he was Director of the Division of Clearing and Risk. Previously, he served as the Director of the former Division of Clearing and Intermediary Oversight.

Latest Articles

The Commodity Futures Trading Commission’s (“CFTC” or “Commission”) Division of Swap Dealer and Intermediary Oversight (“DSIO”) recently issued relief to CFTC-registered swap dealers (“SDs”) from compliance with certain CFTC uncleared swaps margin requirements under two No-Action letters (“NALs”). The relief under these two NALs extends only to those SDs that are obliged to comply with the CFTC’s regulations on margin for uncleared swaps. This excludes SDs who are obliged to comply with the uncleared swaps…
On October 13, 2016, the Commodity Futures Trading Commission (“CFTC’”) unanimously issued an order establishing December 31, 2018 as the swap dealer de minimis threshold phase-in termination date (the “Order”). The Order is effective October 13, 2016. Summary of the Order Pursuant to CFTC Regulation 1.3(ggg), a person shall not be deemed to be a swap dealer (“SD”) unless its swap dealing activity exceeds an aggregate gross notional amount of $3 billion (measured over a rolling…
On October 11, the Commodity Futures Trading Commission (“CFTC’”) issued proposed rules and interpretations (the “Proposed Rule”) addressing the cross-border application of certain swap provisions of the Commodity Exchange Act. Generally speaking, the Proposed Rule aims to: (1) codify certain aspects of the CFTC’s earlier guidance on the cross-border aspects of its swaps regulations (the “Cross-Border Guidance”), (2) amend the list of swaps that would cause a non-U.S. person to be…
The United States Securities and Exchange Commission (SEC) recently finalized a regulation pursuant to Title VII of the Dodd-Frank Act regarding the requirement for security-based swap data repositories (SBSDRs) to make security-based swap data available to other domestic and foreign regulators. Pursuant to the final regulation, SBSDRs must make available security-based swap data, including individual counterparty trade and position data, to several US financial regulators and the Federal Reserve banks, the US Department of Justice,…
ICE Futures US (“ICE”) adopted a new rule, effective March 18, 2016, that provides relief from position limit aggregation requirements applicable to “owned entities.” Specifically, the rule amendment permits certain affiliated entities to disaggregate their positions for purposes of compliance with ICE’s position limits. Background ICE imposes spot-month position limits on all its futures contracts, which limit the number of futures positions (other than those held for bona fide hedging) that a person may hold…
The CFTC has proposed a set of rules, referred to collectively as proposed Regulation AT, that would, for the first time, impose risk control and other requirements governing algorithmic trading systems (ATSs) in futures contracts, options, and swaps traded on designated contract markets (DCMs) such as CME, CBOT, NYMEX, and ICE Futures US.  Regulation AT would impose requirements on:  i) market participants using ATSs (called AT Persons); ii) clearing member futures commission merchants (FCMs)…
CFTC staff has published for public comment a Preliminary Report regarding the level of swap dealing activity that is considered “de minimis” and therefore does not require an entity to register as a swap dealer with the CFTC.  Comments must be filed on or before January 19, 2016. The de minimis threshold        CFTC rules adopted in 2012 set an initial de minimis threshold of $8 billion in aggregate gross notional swaps entered into for “dealing…
On September 17, 2015, the CFTC issued a cease and desist order (“Order”) against Coinflip, Inc. (“Coinflip”) and its CEO for operating a Bitcoin options trading platform in violation of the Commodity Exchange Act (“CEA”) and CFTC rules. In doing so, the CFTC for the first time held that Bitcoin and other virtual currencies are commodities covered by the CEA. The Order found that for approximately 6 months during 2014, Coinflip unlawfully operated an unregistered…
The Commodity Futures Trading Commission (“CFTC” or “Commission”) today proposed amendments to its rules relating to swap data reporting in connection with cleared swaps (the “Proposal”). Comments on the proposal must be submitted to the CFTC 60 days after the Proposal is published in the Federal Register. As of the date of this post, such publication has not taken place. Regulatory history On January 13, 2012, the Commission published part 45 of the Commission’s regulations.…
On August 18, 2015 the Commodity Futures Trading Commission (“CFTC’”) issued an order of exemption from registration as a derivatives clearing organization (“DCO”) to ASX Clear (Futures) Pty Limited (“ASX Clear”) of Sydney, Australia. This is the first exemption of this nature. It is based on the CFTC’s authority under section 5b(h) of the Commodity Exchange Act, which permits the CFTC to exempt a foreign clearing organization from DCO registration for the clearing of swaps…