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
As the House Financial Services Committee letters are also signed by the incoming Chair, they may be interpreted as an expression of willingness to try to use authorities under the Congressional Review Act to overturn federal agency actions taken in the final months of the Biden administration (a potent challenge given that Republicans will control both houses of Congress.)
In addition, many of the letters reference digital asset-related issues. This reinforces the likelihood…
Broker-dealers should closely review this enforcement action as it serves as a clear reminder of how FINRA rules governing communications with the public can apply to the use of social media influencers and certain third-party communications.
While the enforcement action specifically states that the firm "paid [social media influencers] to promote the firm in social media communications," firms should be aware that third parties' social media posts constitute communications with the…
Mr. Bentsen's testimony raises a number of important policy issues the US prudential regulators should consider in re-proposing the Basel III endgame amendments. Of particular note are (i) addressing potential overlaps between the stress testing framework and the current risk-based capital requirements and (ii) reconsideration of the proposed SFT haircut framework, particularly in light of the SEC's Treasury clearing mandate.
Treasury Under Secretary Liang raises the important issue of how current US bank regulatory capital requirements will interact with the SEC's recently adopted US Treasury clearing requirements. This issue does not appear to have been explicitly considered by the federal banking regulators in the current iteration of the Basel III endgame proposal.
As they over the re-proposal of the Basel III endgame, the federal banking regulators should consider the suggestions of Ms. Liang…