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 expected by many market participants, the March 2026 capital proposals reflect a significant reversal of many of the federal banking agencies’ positions in the July 2023 Basel III Endgame proposal (see previous coverage ), while proposing, and expanding on, some of the recommendations made by former Vice Chair for Supervision Michael Barr in his September 2024 speech on the Basel III Endgame proposal (see previous coverage ).
In terms of capital impact, the July 2023 Basel III…
Banking organizations should note that the guidance applies specifically to "tokenized securities that, under applicable law, confer legal rights identical to those of the non-tokenized form of the security" (emphasis added). Accordingly, a banking organization seeking to rely on the guidance must make its own determination as to whether the relevant tokenized security confers identical legal rights as compared to its non-tokenized form. Relatedly, banking organizations must also make their…
The OCC’s proposed rulemaking represents the most consequential regulatory architecture for digital asset activities yet proposed by a U.S. federal banking agency. The agency’s request for comment is sure to generate meaningful discussion and feedback from market participants on various aspects of the payment stablecoin regulatory framework, including addressing, among other things, licensing requirements, reserve asset requirements (which are likely to have implications for U.S. Treasury…
The current U.S. prudential regulatory capital framework only permits a banking organization to recognize the risk-reducing benefits of qualifying cross-product netting arrangements when such banking organization is using the Internal Models Methodology (IMM) to calculate its binding capital requirements, subject to rigorous regulatory approval. However, only the largest banking organizations (i.e., Category I and Category II banking organizations) are subject to the advanced approaches/IMM…