Variation Margin Exchange for Physically-settled FFX Forwards – Last Minute Reprieve?

The Central Bank of Ireland has confirmed its approach to the enforcement of the requirement to exchange variation margin for physically-settled FX forwards (“FFX”) by 3 January 2018 under EMIR.  This follows on from proposed amendments to the regulatory technical standards on risk mitigation techniques for OTC derivatives not cleared by a central counterparty (“Amending RTS”), which were set out in a Final Report published by the European Supervisory Authorities (“ESAs”) on 18 December 2017 (“Final Report”) (here).

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