Key takeaways 

• The CFTC granted limited no-action relief to swap dealers and major swap participants (together, Swap Entities) from compliance with the prohibition against permitting any statutorily disqualified person to effect swaps on their behalf. 
• The no-action relief applies to (1) non-U.S. associated persons of a Swap Entity who deal only with non-U.S. swap counterparties and (2) persons employed by a Swap Entity in a clerical or ministerial capacity.