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
Recission of OCC Interpretive Letter 1179 is further evidence of the significant shift in federal financial regulators' approach to the crypto-asset activities of regulated institutions. Recission of IL 1179 also signals a return to the OCC's view that, for certain bank activities, prior notice to a supervisory office (or examiner-in-charge) is likely sufficient.
Recission of IL 1179 should not be construed to mean that national banks will be conducting crypto-asset activities in an…
Acting SEC Chair Uyeda's and Commissioner Peirce's remarks, collectively, reflect the increasing focus of federal financial regulators on regulated firms' (expanding) uses of AI. Given the increased regulatory focus, broker-dealers and investment advisers should ensure that their use of AI is appropriately supervised at enterprise and individual levels, and that AI-related risks are being appropriately identified and mitigated (including accounting for potential and actual conflicts of…
FRB Governor Bowman is the most likely candidate to replace Michael Barr as Federal Reserve Board Vice Chair for Supervision. Market participants should pay special attention to these remarks in which she outlines various regulatory policy priorities and suggested reforms, which, when taken together, reflect a pragmatic and innovative approach to prudential regulation.
The Associations that they filed the suit, in part, as a way to preserve their ability to challenge the FRB's stress test framework; the six-year statute of limitations to challenge the framework expires in February, 2025.
The opacity of the stress testing framework has been a . The FRB finally appears ready to address it. FRB Governor Michelle Bowman has a number of policy concerns, including the volatility of year-to-year results and regulatory…