In brief On December 9, 2025, the Commodity Futures Trading Commission (CFTC) issued No-Action Letter 25‑42, providing important relief and clarification for market participants navigating cross-border swap requirements. This no-action letter (NAL) addresses longstanding inconsistencies in the definitions of “US person” and “guarantee” across different regulatory requirements and offers practical compliance flexibility. Below is a summary of the key points and why they matter.