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
The Senators raise important questions and concerns that should be carefully considered by the US banking regulators in any adoption of the proposed eSLR reforms. In addition, given the purported value of the eSLR reforms with respect to enhancing Treasury market intermediation, it would be useful for the US banking regulators to consider how reform of the eSLR is interconnected with the impact of the SEC's Treasury clearing mandate.
Senator Warren’s queries collectively raise an important question with respect to the threshold for activation of the CCyB: When exactly does the FRB consider “systemic vulnerabilities” to be “meaningfully above normal” such that the CCyB should be activated? The answer to this question is particularly important in light of the FRB’s findings in the April 2025 Financial Stability Report which, collectively, would appear to illustrate increased financial system vulnerabilities.
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Mr. Barr's remarks raise important questions about the value of countercyclical financial regulation, particularly as financial regulatory tools have historically tended to be procyclical. As policymakers reexamine the value of the Dodd-Frank Act's regulations, they should reevaluate the efficacy of the countercyclical mechanisms thereunder.
One area where fragmentation is of particular concern is regulatory capital. Material jurisdictional variations in regulatory capital requirements have the potential to lead to a "race to the bottom" on capital, which in turn would have serious consequences for financial stability and systemic risk. Jurisdictional differences in capital regulation can also lead to increased compliance costs for firms to the extent that such regulatory differences across jurisdictions necessitate distinct…