Senior Associate
Norton Rose Fulbright US LLP
Sebastian Souchet focuses his practice on representing US and non-US banks, broker-dealers and “buy-side” market participants on bank regulatory matters and regulatory, transactional and compliance issues related to securities and derivatives.
More specifically, Sebastian has experience advising US and non-US banks, bank holding companies, and other financial market participants on various bank regulatory issues including capital requirements, licensing/chartering requirements, control issues, affiliate and insider transactions, and the Volcker Rule.
Sebastian also has experience representing US and non-US banks and broker-dealers on various requirements arising under the US securities laws and the Commodity Exchange Act, including requirements relating to trading, supervision, recordkeeping, reporting, capital, margin and communications/marketing, as well as SEC and CFTC regulatory requirements arising under Title VII of the Dodd-Frank Act.
Sebastian also advises clients on complex financial transactions and has experience drafting and negotiating securities and derivatives trading documentation, including prime brokerage agreements, ISDA Master Agreements and various other industry-standard and bespoke trading and financing contracts.
Recent Articles & Comments
Notably, the FRB identifies as a significant risk, that a U.S. CBDC may lead to a disintermediation of private sector financial institutions by allowing investors to hold their money directly with the government, rather than through a bank or money market fund.
is a law clerk in the Financial Services Practice. Fried Frank's contributed to this comment.
Ms. Massari and Ms. Allen reject - each for separate (but not unrelated) reasons - the of the PWG to regulate stablecoin issuers as insured depository institutions. While Ms. Massari identifies several economic and regulatory issues posed by applying the insured depository institution framework to the stablecoin business model, Ms. Allen emphasizes the various systemic consequences and risks of regulating stablecoin issuers under that framework. On the whole, U.S. policymakers and financial…
Mr. Quarles' comments on digital assets are intriguing, if for no other reason than his somewhat surprising praise of such assets as a "welcome innovation." Previous comments by Mr. Quarleswith respect to a Federal Reserve-issued central bank digital currency, and may have been interpreted by some as a general skepticism of the digital asset space overall. Yet, his farewell remarks make clear his view that financial regulators should "welcome responsible innovation...[and] create a…
Ripple states that “technologies like cryptocurrency and blockchain require new regulatory paradigms” (emphasis added). Yet, fundamentally, Ripple’s proposal is to establish cryptocurrency regulation through the use of existing financial regulatory frameworks. As with , critical questions remain unanswered:
How will use of existing financial regulatory frameworks adequately account for the extent to which digital asset markets operate differently from traditional financial markets?…