1

iSwap SEF Application

Exhibit L – Compliance Chart: Application and Compliance with Core Principles
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Attach a narrative and any other form of documentation that may be provided 

under other Exhibits herein, that describes the manner in which iSwap Euro B.V. 

is able to comply with each core principle. Such documentation must include a 

regulatory compliance chart setting forth each core principle and providing 

citations to the iSwap Euro’s relevant rules, policies, and procedures that 

address each core principle. To the extent that the application raises issues that 

are novel or for which compliance with a core principle is not self-evident, 

include an explanation of how that item and the application satisfy the core 

principles
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Swap Execution Facility Registration and 

Core Principles

iSwap Euro Swap Execution Facility 

Application 

Relevant Documents, Rules or Agreements

Core Principle 1 

Compliance with Core Principles

(A) In general

To be registered, and maintain registration, 

as a swap execution facility, the swap 

execution facility shall comply with—

(i) the core principles described in this 

subsection; and

(ii) any requirement that the Commission 

may impose by rule or regulation pursuant to 

section 8a(5).

(B) Reasonable discretion of swap 

execution facility

Unless otherwise determined by the 

Commission by rule or regulation, a swap 

execution facility described in 

subparagraph (A) shall have reasonable 

discretion in establishing the manner in which 

the swap execution facility complies with the 

core principles described in this subsection.

The application of iSwap Euro B.V. ("iSwap 

Euro") as a whole satisfies this Core Principle.

Capitalized terms used in this Exhibit L but 

undefined have the meanings ascribed thereto in 

the iSwap Euro Venue Rulebook submitted under 

Exhibit M-1 (the “Venue Rulebook”).

iSwap Euro Application and supporting 

documentation

Articles of Association (Exhibit G-1)

Governance Policy (Exhibit G-3)

Financial Information (Exhibit I)

Venue Rulebook (Exhibit M-1)

Order Book Market Appendix (Exhibit M-2)

Targeted Streaming Market Appendix 

(Exhibit M-3)

Schedule (Exhibit M-5)

List of agreements that enable iSwap Euro 

to comply with Core Principles (Exhibit N-1)

EMEA Compliance Manual (Exhibit O)

Disciplinary Procedures (Exhibit P)

Operational Manual (Exhibit Q)

Trading Standards (Exhibit R)
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Core Principle 2 

Compliance with Rules

A swap execution facility shall—

(A) establish and enforce compliance with 

any rule of the swap execution facility, 

including—

(i) the terms and conditions of the swaps 

traded or processed on or through the swap 

execution facility; and

(ii) any limitation on access to the swap 

execution facility; 

(B) establish and enforce trading, trade 

processing, and participation rules that will

deter abuses and have the capacity to detect, 

investigate, and enforce those rules, 

including means—

(i) to provide market participants with 

impartial access to the market; and

(ii) to capture information that may be used in 

establishing whether rule violations have 

occurred;

(C) establish rules governing the operation of 

the facility, including rules specifying trading 

procedures to be used in entering and 

executing orders traded or posted on the 

facility, including block trades; and

(D) provide by its rules that when a swap 

dealer or major swap participant enters into 

iSwap Euro has established rules and procedures 

reasonably designed to demonstrate compliance 

with Section 5h of the Commodity Exchange Act 

(the “CEA”) and the regulations of the Commodity 

Futures Trading Commission (the “Commission”), 

including rules and procedures enforcing 

compliance with the Venue Rulebook, setting the 

terms and conditions of swaps traded on the 

Venue, providing for impartial access to the 

Venue, establishing trading procedures and 

surveillance and real time monitoring of trading, 

and addressing applicable mandatory clearing 

and mandatory trading requirements under the 

CEA.

The Venue Rulebook and Exhibit O (EMEA 

Compliance Manual) provide the framework for 

iSwap Euro's compliance with regulatory, legal, 

and internal rules, policies and procedures, as 

well as monitoring and enforcement activities.

Chapter 3 to 6 of the Venue Rulebook set forth 

the obligations and fitness standards to become 

and remain a Participant; either a Member 

Participant or a Broker Participant. 

Rule 4.1.6 and Chapter 17 of the Venue Rulebook 

require Member Participants that enter into a 

swap subject to mandatory clearing under section 

2(h) of the CEA to be responsible for compliance 

Governance Policy (Exhibit G-3)

Section 11. Compliance Function

Venue Rulebook (Exhibit M-1)

Chapter 3. Participation

Chapter 4. Eligibility Criteria for Member 

 Participants 

Chapter 5. Eligibility Criteria for Broker 

 Participants

Chapter 6. Participant Obligations

Chapter 9. Conduct Rules

Chapter 14. Trading Rules

Chapter 15. Trade Cancellations and Error 

 Trades

Chapter 17. Clearing and Settlement

Chapter 28. Governing Law

Order Book Market Appendix (Exhibit M-2)

Chapter 5. Trading Rules
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or facilitates a swap that is subject to the 

mandatory clearing requirement of 

section 2(h), the swap dealer or major swap 

participant shall be responsible for 

compliance with the mandatory trading 

requirement under section 2(h)(8).

with the mandatory trading requirement under 

section 2(h)(8) of the CEA. 

The Venue requires that Participants will receive 

impartial access to its market(s) and market 

services. See Rule 5.10 of the Order Book Market 

Appendix (Exhibit M-2).

Pursuant to Rule 4.1.1. and Rule 5.1.1. of the

Venue Rulebook, Member Participants and 

Broker Participants must be eligible contract 

participants (“ECPs”) to be granted access to the 

Venue. 

Chapters 6, 9 and 14 of the Venue Rulebook and 

Exhibit R (Trading Standards) set forth trading 

practices that must be followed by Participants. 

The Order Book Market Appendix (Exhibit M-2) 

provide for Participants' access to the Venue's 

Order Book. Rule 14.8 of the Venue Rulebook 

establishes rules governing execution of Required 

Transactions applicable to all Participants. 

Chapter 9 of the Venue Rulebook and Section 5 

and 6 of Exhibit R (Trading Standards) specifically 

prohibit activities such as manipulation, price 

distortion and disruptive trading practices. In the 

EMEA Compliance Manual (Exhibit O) is 

described the manner in which iSwap manages 

conflicts of interest fairly between both itself, its 

staff and its customers and between a customer 

and another client. Additionally, the Venue has 

adopted a Conflicts of Interest Management 

Policy that addresses, among other things, any 

potential conflicts that may arise form external 

employers.

EMEA Compliance Manual (Exhibit O)

Section B.4. Record Keeping

Section E.1. Conflicts of Interest

Section F.1. AML/CTF 

Disciplinary Procedures (Exhibit P)

Section 1. Jurisdiction

Section 2. iSwap Venue Compliance Function 

Powers and Duties

Section 9. Settlement Prior to Commencement 

 of Hearing

Section 10. Hearing Procedures

Section 11. Written Decision of Hearing Panel

Trading Standards (Exhibit R)

Section 5. Manipulation and Price Distortion

Section 6. Disruptive Trading Practices
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Rule 9.3 of the Venue Rulebook and Exhibit P 

(Disciplinary Procedures) govern the Venue’s 

disciplinary procedures, including the initiation 

and adjudication of proceedings and the 

imposition of sanctions. Section 1 of Exhibit P 

(Disciplinary Procedures) provides that iSwap 

Euro has the authority to initiate and conduct 

investigations, and prosecute Violations of the 

Venue Rulebook and impose sanctions for such 

Violations. Section 9 and 10 of Exhibit P 

(Disciplinary Procedures) require such sanctions 

to be commensurate with the violations committed 

and are clearly sufficient to deter recidivism or 

similar violations by other market participants, 

including by setting forth minimum and maximum 

fine amounts. The Venue has the ability to 

sanction, including by fine, suspension and/or 

expulsion, all persons under Section 1 and 11 of

Exhibit P (Disciplinary Procedures). Pursuant to 

Section 14 of Exhibit P (Disciplinary Procedures), 

iSwap Euro may summarily and immediately 

suspend Participants from trading on the Venue 

when the Chairperson of the Regulatory 

Oversight Committee (“ROC”) determines such 

action is necessary to protect the best interests of 

the market place.

The Compliance Function, which consists of the 

Chief Compliance Officer (“CCO”) and the 

Compliance Department, as well as the 

Regulatory Services Provider under the 

supervision of the Compliance Function, will 

implement the iSwap Euro's monitoring, 

surveillance and other enforcement functions, and 
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the iSwap Euro Board of Directors (the “Board”) 

and ROC will oversee this activity. The CCO is 

appointed by the Board and must meet with the 

ROC at least quarterly. The CCO has sufficient 

staff and resources to develop and enforce rules, 

policies and procedures necessary to fulfil the 

CCO’s duties to the Venue and obligations under 

the CEA and Commission Regulations.

The Venue has Rules that provide it with the 

authority to collect and examine books and 

records of Participants, including all persons 

under investigations. See Rules 6.12 and 20.2 of 

the Venue Rulebook as well as Section 2 of the 

Disciplinary Procedures (Exhibit P).

Section 11 of the Governance Policy (Exhibit G-3) 

also provides that the CCO shall undertake the 

necessary steps to demonstrate that the Venue 

conforms the Venue Rulebook.

iSwap Euro has contracted with ICAP 

Management Services Limited ("IMSL") as a 

Regulatory Services Provider (“RSP”) to perform 

regulatory services including conducting trade 

and market surveillance for activities on the 

Venue. However, the Compliance Function 

maintains responsibility for supervision of IMSL 

and the CCO is ultimately responsible for the 

compliance program of the Venue as it relates to 

the CEA and the Commission’s Regulations. See

“Core Principle 4 – Monitoring of Trading and 

Swap Processing.” IMSL will also perform certain 

preliminary investigations related to trade practice 

and market surveillance, and may request 
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information directly from Participants and prepare 

investigative summaries of its findings.

iSwap Euro has the ability to conduct real time 

monitoring of trading activity in order to identify 

disorderly trading and market anomalies, and 

Rule 15.2 of the Venue Rulebook allows iSwap 

Euro to adjust trade prices or cancel trades when 

necessary to mitigate market disrupting events. 

iSwap Euro also has robust recordkeeping and 

audit trail rules and procedures that are 

reasonably designed to allow iSwap Euro to 

identify trading violations and reconstruct all 

indications of interest, RFQs, orders and trades 

within a reasonable amount of time. See Rule 

20.2 of the Venue Rulebook and Section B.4 of 

Exhibit O (EMEA Compliance Manual).

Chapter 28 of the Venue Rulebook states that all 

parties (including Authorised Persons) 

acknowledge and submit to the jurisdiction of the 

Venue.

Core Principle 3 

Swaps Not Readily Susceptible to 

Manipulation

The swap execution facility shall permit 

trading only in swaps that are not readily 

susceptible to manipulation.

Rule 13.4 of the Venue Rulebook provides that 

iSwap Euro will permit trading only in instruments 

that are not readily susceptible to manipulation 

before submitting any swap to the Commission for 

prior approval or with self-certification. The CCO 

must include all information required by Appendix 

C to Part 38 of the Commission Regulations in 

any swap submission to the Commission when 

submitting contracts for approval or certification 

as per Part 40 of the Commission Regulations.

Venue Rulebook (Exhibit M-1)

Chapter 13. Products
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Core Principle 4 

Monitoring of trading and trade 

processing 

The swap execution facility shall—

(A) establish and enforce rules or terms and 

conditions defining, or specifications 

detailing—

(i) trading procedures to be used in entering 

and executing orders traded on or through 

the facilities of the swap execution facility; 

and 

(ii) procedures for trade processing of swaps 

on or through the facilities of the swap 

execution facility; and

(B) monitor trading in swaps to prevent 

manipulation, price distortion, and disruptions 

of the delivery or cash settlement process 

through surveillance, compliance, and 

disciplinary practices and procedures, 

including methods for conducting real-time 

monitoring of trading and comprehensive and 

accurate trade reconstructions.

Chapter 9 and 14 of the Venue Rulebook, the

Order Book Market Appendix (Exhibit M-2), the 

Targeted Streaming Market Appendix (Exhibit M3) and Exhibit R (Trading Standards) set forth 

trading practices that must be followed when 

entering orders and RFQs into the Venue and 

when executing such orders and RFQs.

Rule 9.3 of the Venue Rulebook and Exhibit P 

(Disciplinary Procedures) describe iSwap Euro’s 

disciplinary and enforcement procedures. See 

“Core Principle 2 – Compliance with Rules.”

iSwap Euro has contracted with IMSL as a 

Regulatory Services Provider to perform 

regulatory services including conducting trade 

and market surveillance for activities on the 

Venue. The Compliance Function, Market Control 

Staff, Market Regulation Staff and Regulatory 

Services Provider will implement iSwap Euro’s 

monitoring, surveillance and other enforcement 

functions, and the Board and ROC will oversee 

this activity. Exhibit Q (Operational Manual) 

provides the framework for market control 

procedures, including monitoring of trades on the 

Venue. The Venue Rulebook and Exhibit P 

(Disciplinary Procedures) provide the framework 

for iSwap Euro’s enforcement activities.

iSwap Euro captures all trade and order data, 

including modifications and cancellations. IMSL 

has developed an automated trade surveillance 

system that performs trade practice and market 

Venue Rulebook (Exhibit M-1)

Chapter 9. Conduct Rules

Chapter 14. Trading Rules

Order Book Market Appendix (Exhibit M-2)

Chapter 5. Trading Rules

Targeted Streaming Market Appendix 

(Exhibit M-3)

Chapter 5. Trading Rules

EMEA Compliance Manual (Exhibit O)

Section B.4. Record Keeping

Services Agreement with IMSL (Exhibits N2)

Schedule 1. The Services 

Disciplinary Procedures (Exhibit P)

Operational Manual (Exhibit Q)

Section 3.5.2. Market Control

Section 4.4. Monitoring Order in i-Swap

Section 4.11. Monitoring
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surveillance. IMSL is also responsible for 

reviewing the Venue’s trades on a routine basis to 

determine whether suspicious activity relating to

iSwap Euro’s trading standards exists. The 

performance of IMSL's functions is supervised by 

the Compliance Function and specifically by the 

CCO as it relates to the CEA and the 

Commission’s Regulations.

iSwap Euro and its Participants are subject to 

certain audit trail requirements set out in Rule 

20.2 to 20.5 of the Venue Rulebook as well as in 

Section B.4 of the Exhibit O (EMEA Compliance 

Manual), which taken together assure iSwap 

Euro’s ability to comprehensively and accurately 

reconstruct all trading on the Venue. See also 

“Core Principle 10 – Recordkeeping and 

Reporting.”

Trading Standards (Exhibit R)

Core Principle 5 

Ability to obtain information

The swap execution facility shall—

(A) establish and enforce rules that will allow 

the facility to obtain any necessary 

information to perform any of the functions 

described in this section;

(B) provide the information to the 

Commission on request; and

(C) have the capacity to carry out such 

international information-sharing agreements 

as the Commission may require.

The Venue Rulebook sets forth the requirements 

of Participants to maintain books and records and 

to permit inspection and visitation by duly 

authorized representatives of the Commission. 

See Rules 6.11 and 6.12 of the Venue Rulebook.

Exhibit P (Disciplinary Procedures) describes 

iSwap Euro’s disciplinary and enforcement 

procedures. See also “Core Principle 2 –

Compliance with Rules.” In Section 2 of Exhibit P 

(Disciplinary Procedures) is set out that the 

Compliance Function of iSwap Euro shall have 

the authority to inspect the books and records of 

all Participants and the authority to require any 

Venue Rulebook (Exhibit M-1)

Chapter 6. Participant Obligations

Chapter 23. Co-operation with Regulators

Chapter 26. Confidentiality

Disciplinary Procedures (Exhibit P)

Section 2. iSwap SEF Compliance Function 

 Powers and Duties
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Participants staff to appear before it to answer 

questions regarding matters being investigated.

It is iSwap Euro’s policy to respond promptly and 

completely, through the Compliance Function, to 

any proper regulatory inquiry or request for 

documents. See also Rule 23.2 of the Venue 

Rulebook. 

In addition, as appropriate, iSwap Euro may enter 

into information sharing agreements or other 

arrangements or procedures to co-ordinate 

surveillance with other markets on which 

contracts or financial instruments related to the 

contracts trade. As part of these agreements, 

iSwap Euro may, in part: (i) provide market 

surveillance reports to other Venues; (ii) share 

information and documents concerning current 

and former Participants with other markets; 

(iii) share information and documents concerning 

ongoing and completed investigations with other 

markets; and/or (iv) require its current or former 

Participants to provide information and 

documents to iSwap Euro at the request of other 

markets with which iSwap Euro has an 

information sharing agreement or other 

arrangements or procedures. See also Rule 26.1 

of the Venue Rulebook.

iSwap Euro will enter into international information 

sharing agreements as the Commission may 

require from time to time.

Core Principle 6 

Position Limits or Accountability Trading Standards (Exhibit R)
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(A) In general 

To reduce the potential threat of market 

manipulation or congestion, especially during 

trading in the delivery month, a swap 

execution facility that is a trading facility shall 

adopt for each of the contracts of the facility, 

as is necessary and appropriate, position 

limitations or position accountability for 

speculators.

(B) Position limits

For any contract that is subject to a position 

limitation established by the Commission 

pursuant to section 4a(a), the swap execution 

facility shall—

(i) set its position limitation at a level no 

higher than the Commission limitation; and 

(ii) monitor positions established on or 

through the swap execution facility for 

compliance with the limit set by the 

Commission and the limit, if any, set by the 

swap execution facility.

Section 8 of Exhibit R (Trading Standards) 

requires that iSwap Euro set and enforce any 

applicable position limits and position 

accountability levels with respect to each swap 

traded on the Venue as is necessary and 

appropriate. Participants that are in violation of 

position limits will be prohibited from trading on 

the Venue, except to liquidate open positions. 

iSwap Euro has adopted the Commission’s 

position limits for any swap for which the 

Commission has adopted a position limit. The 

Compliance Function will continue to assess 

whether additional position limits or position 

accountability levels are necessary or appropriate 

and should be adopted by the Venue. The 

Compliance Function (including IMSL) will monitor 

for positions that meet or exceed reportable 

levels.

Section 8. Position Limits and Position 

 Accountability

Core Principle 7 

Financial Integrity of Transactions

The swap execution facility shall establish 

and enforce rules and procedures for 

ensuring the financial integrity of swaps 

entered on or through the facilities of the 

swap execution facility, including the 

clearance and settlement of the swaps 

pursuant to section 2(h)(1).

Financial Requirements

Each Member Participant and Broker Participant 

must be an ECP in order to be approved as such. 

Each Member Participant and Broker Participant 

must immediately notify iSwap Euro upon 

becoming aware that it no longer continues to be 

an ECP. See Rules 4.1.1, 5.1.1. and 8.1.6 of the 

Venue Rulebook. As noted above, Chapter 28 of 

Venue Rulebook (Exhibit M-1)

Chapter 4. Eligibility Criteria for Member 

 Participants

Chapter 5. Eligibility Criteria for Broker 

 Participants

Chapter 6. Participant Obligations
13

the Venue Rulebook requires parties to consent 

to iSwap Euro’s jurisdiction.

iSwap Euro’s Rules require that each Member 

Participant and Broker Participant be an ECP at 

the time of entering into any transaction on the 

Venue and requires written or electronic 

confirmation of such ECP status (to be provided 

during the client on-boarding process). Each 

Member Participant transacting on the Venue in

cleared swaps as a principal is required to provide 

iSwap Euro with evidence that it is able to fulfil the 

Derivatives Clearing Obligation from section 2(h) 

of the CEA. See also Rule 4.1.6 of the Venue 

Rulebook. iSwap Euro requires Broker Participant 

to have and continue to have the legal and 

regulatory capacity to deal on behalf of Member 

Participants being ECPs. See Rule 5.1.2 of the 

Venue Rulebook.

Participants are required to notify iSwap Euro 

when there are material changes in the 

information submitted to iSwap Euro, including a 

change in status as an ECP. See Chapter 8 of the 

Venue Rulebook.

Clearing

All Products available for trading on the Venue 

are subject to mandatory clearing under the 

Regulation of the European Parliament and of the 

Council on OTC derivatives, central 

counterparties and trade repositories (No. 

648/2012/EU), as amended from time to time 

(“EMIR”) and Section 2(h) of the CEA. Member 

Chapter 8. Notification

Chapter 10. Suspension or Termination of 

 Participation

Chapter 17. Clearing and Settlement

Chapter 20. Information and Data

Chapter 28. Governing Law

Participant Agreement (Exhibit N-8)

Attachment A. Authorised Trader Application

EMEA Compliance Manual (Exhibit O)

Section C.3. Client Onboarding

Disciplinary Procedures (Exhibit P)

Section 1. Jurisdiction

Section 2. iSwap SEF Compliance Function 

 Powers and Duties

Section 11. Written Decision of Hearing Panel

Section 14. Summary suspension

Operational Manual (Exhibit Q)

Section 6.5. Client On-Boarding
14

Participants are responsible for the clearing and 

the settlement of all Trades on the Venue. 

Member Participants must ensure they have the 

facility to clear and settle all Trades on the Venue 

in accordance with regulatory requirements and 

market practice. The Venue has the capacity to 

send the information related to each Trade 

executed on the Venue to the relevant Clearing 

House through an Affirmation Hub as soon as 

technologically practicable after the execution of 

the Trade. See Rules 4.1.6, 17.1, 17.2 and 17.6 

of the Venue Rulebook.

Onboarding

Market Control Staff will review each application 

made to become a Participant and will verify that 

the applicant has stated in its application that it is 

an ECP. Market Control Staff sign-off of this 

requirement will be required for approval of the 

application. Participant must notify iSwap Euro in 

writing of the names of those individuals 

authorised by the Participant to be Authorised 

Persons on the Venue and its designated Markets 

and/or Products. See Rule 6.3 of the Venue 

Rulebook, Section 6.5. of the Operational Manual 

(Exhibit Q), Participant Agreement (Exhibit N-8) 

and Section C.3. of the EMEA Compliance 

Manual (Exhibit O).

Enforcement of Rules

iSwap Euro has the authority to collect and 

examine books and records of all Participants 

under Rules 6.11, 6.12 and 20.2 of the Venue 
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Rulebook. If Market Control Staff and/or Market 

Regulation Staff at any time determines that a 

Participant no longer meets the financial 

requirements, the Compliance Function will report 

the matter to the Chairperson of the ROC, who 

may suspend the trading privileges of the 

Participant pursuant to Rule 10.1.5 of the Venue 

Rulebook and Section 14 of Exhibit P 

(Disciplinary Procedures), and the Compliance 

Function may also report the matter to the Review 

Panel for possible disciplinary action pursuant to 

Section 2 of Exhibit P (Disciplinary Procedures). 

Furthermore, iSwap Euro has the ability to 

sanction, including by fine, suspension and/or 

expulsion, all persons under Section 1 and 11 of

Exhibit P (Disciplinary Procedures).

Core Principle 8 

Emergency Authority

The swap execution facility shall adopt rules 

to provide for the exercise of emergency 

authority, in consultation or cooperation with 

the Commission, as is necessary and 

appropriate, including the authority to 

liquidate or transfer open positions in any 

swap or to suspend or curtail trading in a 

swap.

The Venue Rulebook set forth clear procedures 

and guidelines for decision making regarding 

emergency intervention in the market, including 

procedures and guidelines to avoid conflicts of 

interest while carrying out such decision making.

iSwap Euro may take any remedial action 

deemed necessary in the case of an Emergency 

including: the authority to liquidate or transfer 

open positions in any swap or to suspend or 

curtail trading in a swap. See Rule 14.22 of the 

Venue Rulebook.

iSwap Euro will notify the Commission in 

accordance with Part 40 of the Commission’s 

Regulations of implementing, modifying, or 

terminating any Emergency Rule and will 

Venue Rulebook (Exhibit M-1)

Chapter 14. Trading Rules

Schedule (Exhibit M-5)

Section 8. Exceptional Circumstances
16

comprehensively document the decision making 

process related to any action in response to an 

emergency.

Core Principle 9 

Timely Publication of Trading Information

(A) In general

The swap execution facility shall make public 

timely information on price, trading volume, 

and other trading data on swaps to the extent 

prescribed by the Commission.

(B) Capacity of swap execution facility 

The swap execution facility shall be required 

to have the capacity to electronically capture 

and transmit trade information with respect to 

transactions executed on the facility.

iSwap Euro will timely transmit swap transaction 

and pricing data to a registered swap data 

repository (“SDR”) that accepts swap data for 

swaps traded on the Venue. iSwap Euro will also 

timely publish information on the iSwap website 

as required under Part 16 of the Commission’s 

Regulations. Rule 19.1 of the Venue Rulebook 

requires iSwap Euro to publish trading information 

as required by Core Principle 9, Commission 

Regulation §37.901 and Part 16 of the 

Commission Regulations. 

All swap data will be reported in accordance with 

Part 43 and Part 45 of the Commission 

Regulations. Rule 19.3 of the Venue Rulebook 

sets forth the procedures governing how iSwap 

Euro reports transactions to SDRs, including how 

iSwap Euro determines which SDR to report a 

transaction to. 

Venue Rulebook (Exhibit M-1)

Chapter 18. Pre-Trade and Post-Trade 

 Publication

Note to draft: may need to address Rules 18.2 

and 18.3 re: waived or delayed trade reporting 

and consistency with CFTC rules. 

Chapter 19. Trade Reporting

iSwap Website 

https://mifidiidata.i-swap.com/login.html

https://www.tpicapmifidiidata.com/transparencydata

Core Principle 10 

Recordkeeping and Reporting 

(A) In general

A swap execution facility shall— (i) maintain 

records of all activities relating to the 

business of the facility, including a complete 

iSwap Euro will maintain records of all activities 

related to its business for a period of five (5) years 

in accordance with Commission Regulations. See 

Section B.4 of Exhibit O (EMEA Compliance 

Manual). Each Participant is also obliged to 

maintain all requisite books and records in 

accordance with Commission Regulations. All 

Venue Rulebook (Exhibit M-1)

Chapter 6. Participant Obligations

Chapter 20. Information and Data

Chapter 23. Co-operation with Regulators
17

audit trail, in a form and manner acceptable 

to the Commission for a period of 5 years;

(ii) report to the Commission, in a form and 

manner acceptable to the Commission, such 

information as the Commission determines to 

be necessary or appropriate for the 

Commission to perform the duties of the 

Commission under this chapter; and

(iii) shall keep any such records relating to 

swaps defined in section 1a(47)(A)(v) open to 

inspection and examination by the Securities 

and Exchange Commission.”

(B) Requirements

The Commission shall adopt data collection 

and reporting requirements for swap 

execution facilities that are comparable to 

corresponding requirements for derivatives 

clearing organizations and swap data 

repositories.

such records will be open to inspection by the 

Commission, U.S. Securities and Exchange 

Commission or U.S. Department of Justice. See 

Rules 6.11, 6.12, 20.2 through 20.5, and 23.2 of 

the Venue Rulebook.

iSwap Euro will respond promptly and completely, 

through the Legal and Compliance Departments, 

to any proper regulatory inquiry or request for 

documents from the Commission, IMSL, or other 

regulatory or law enforcement agency. See Rule 

23.2 of the Venue Rulebook and Section 4.11.3 of 

the Operational Manual (Exhibit Q).

EMEA Compliance Manual (Exhibit O)

Section B.4. Record Keeping

Operational Manual (Exhibit Q)

Section 4.11.3. Alerts and Status'

Core Principle 11 

Antitrust Considerations

Unless necessary or appropriate to achieve 

the purposes of this CEA , the swap 

execution facility shall not—

(A) adopt any rules or taking any actions that 

result in any unreasonable restraint of trade; 

or 

(B) impose any material anticompetitive 

burden on trading or clearing.

The Venue Rulebook and iSwap Euro's policies 

have been designed to avoid any unreasonable 

restraints on trade or the imposition of any 

material anti-competitive burden on trading. 

iSwap Euro has not adopted any rule or taken any 

action with the intent or result of restraining trade. 

In particular, iSwap Euro will not limit a 

Participant’s choice of Clearing Firm or DCO. 

Additionally, iSwap Euro will not limit any SDR’s 

ability to compete for iSwap Euro’s business. 

iSwap Euro may request that the Commission 

Venue Rulebook (Exhibit M-1)

Chapter 4. Eligibility Criteria for Member 

 Participants
18

consider under the provisions of Section 15(b) of 

the CEA any of iSwap Euro's policies for 

compliance with Core Principle 11. 

iSwap Euro will not require Participants to acquire 

an equity interest in iSwap Euro.

Core Principle 12 

Conflicts of Interest

The swap execution facility shall—

(A) establish and enforce rules to minimize 

conflicts of interest in its decision-making 

process; and 

(B) establish a process for resolving the 

conflicts of interest.

iSwap Euro’s Governance Policy, Venue 

Rulebook and Conflicts of Interest Management 

Policy minimize conflicts of interest in decision 

making processes and contain methods to 

ascertain the presence of conflicts of interest and 

to make decisions in the event of such a conflict. 

No member of the Board, member of any 

committee, officer or other person authorised to 

exercise authority on behalf of iSwap Euro may 

knowingly participate in any deliberations or vote 

if such person has a conflict of interest between 

his or her position with iSwap Euro and such 

person’s personal interests.

In addition, the Venue Rulebook contains 

limitations on the use and disclosure of material 

non public information by Board members and 

iSwap Euro personnel gained through 

performance of their duties. 

Exhibit O (EMEA Compliance Manual) 

establishes standards regarding conflicts of 

interests, employee trading and all iSwap Euro 

personnel must comply with the Code of Conduct, 

which addresses, among other things, potential 

conflicts of interest related to external 

employment by iSwap Euro affiliates.

Governance Policy (Exhibit G-3)

Section 4. Conflicts of Interest

Venue Rulebook (Exhibit M-1)

Chapter 26. Confidentiality

EMEA Compliance Manual (Exhibit O)

Section B.1. Code of Conduct

Section B.3. Confidentiality

Section E.1. Conflicts of Interest

Section G.1. Insider Dealing

Section G.2. Unlawful Disclosure of Inside 

 Information

Section G.6. Personal Account Dealing

Disciplinary Procedures (Exhibit P)

Section 7. Challenge to Members of the 

 Hearing Panel
19

Pursuant to Section 7 of Exhibit P (Disciplinary 

Procedures), a Respondent may seek to 

disqualify any individual named to a Hearing 

Panel for cause, including without limitation, if the 

member has a direct financial, personal or other 

interest in the matter under consideration.

Core Principle 13 

Financial Resources

(A) In general

The swap execution facility shall have 

adequate financial, operational, and 

managerial resources to discharge each 

responsibility of the swap execution facility.

(B) Determination of resource adequacy

The financial resources of a swap execution 

facility shall be considered to be adequate if 

the value of the financial resources exceeds 

the total amount that would enable the swap 

execution facility to cover the operating costs 

of the swap execution facility for a 1-year 

period, as calculated on a rolling basis.

iSwap Euro will maintain adequate financial, 

operational, and managerial resources to 

discharge each responsibility of iSwap Euro. 

Specifically, iSwap Euro will maintain assets that 

exceed the total amount that would enable iSwap 

Euro to cover its operating costs for a period of at 

least one year, calculated on a rolling basis, with 

six months’ operating costs being in liquid assets. 

If any portion of iSwap Euro’s financial resources 

is not sufficiently liquid, capital infusions would be 

provided by iSwap Euro’s parent group for the 

purpose of meeting the requirement to have six 

months’ operating costs in liquid assets.

Financial Information (Exhibit I)

Core Principle 14 

System Safeguards

The swap execution facility shall—

(A) establish and maintain a program of risk 

analysis and oversight to identify and 

minimize sources of operational risk, through 

the development of appropriate controls and 

procedures, and automated systems, that—

As a member of the TP ICAP group, iSwap Euro 

has adopted TP ICAP Plc’s Business Continuity 

Management Policy and other policies and 

procedures regarding the establishment of system 

safeguards such as the Operational Manual 

(Exhibit Q).

Operational Manual (Exhibit Q)

Section 7. Platform Support and Disaster 

 Recovery

Section 8. Software Development and Change 

 Control
20

(i) are reliable and secure; and 

(ii) have adequate scalable capacity;

(B) establish and maintain emergency 

procedures, backup facilities, and a plan for 

disaster recovery that allow for—

(i) the timely recovery and resumption of 

operations; and 

(ii) the fulfillment of the responsibilities and 

obligations of the swap execution facility; and

(C) periodically conduct tests to verify that the 

backup resources of the swap execution 

facility are sufficient to ensure continued—

(i) order processing and trade matching;

(ii) price reporting; 

(iii) market surveillance and 

(iv) maintenance of a comprehensive and 

accurate audit trail.

The TP ICAP system safeguard policies and 

procedures address risk management, technology 

testing and maintenance, information security, 

system safeguards and security tools, security 

testing, security incident handling procedures and 

management processes, quality assurance and 

test trades. TP ICAP conducts regular, periodic 

testing and review of iSwap Euro’s automated 

systems.

The TP ICAP Business Continuity Management 

Policy is designed to ensure that iSwap Euro is 

able to resume its operations and fulfill its 

responsibilities and obligations during the next 

business day following any disruption of its 

operations through the use of alternate TP ICAP 

sites. TP ICAP conducts regular, periodic testing 

and review of the Business Continuity 

Management Policy. Upon request, the 

Compliance Function will provide the Commission 

with a copy of the Business Continuity 

Management Policy or other relevant documents 

for the purpose of the Commission maintaining a 

current profile of iSwap Euro’s automated 

systems.

Section 9. Networking, Hardware and Security

Section 10. Platform Security and 

 Administration

Business Continuity Plan (Exhibit V-26) 

Core Principle 15

Designation of Chief Compliance Officer 

(A) In general

Each swap execution facility shall designate

an individual to serve as a chief compliance 

officer.

(B) Duties

iSwap Euro has designated a CCO. The CCO 

reports directly to the Board of Directors and 

meets at least annually with the Board. Likewise, 

the CCO meets with the ROC at least once a 

quarter to discuss compliance related matters. 

The CCO is responsible for ensuring compliance 

with the Venue Rulebook and policies and 

Governance Policy (Exhibit G-3)

Section 11. Compliance Function
21

The chief compliance officer shall—

(i) report directly to the board or to the senior 

officer of the facility; (ii) review compliance 

with the core principles in this subsection; (iii)

in consultation with the board of the facility, a 

body performing a function similar to that of a 

board, or the senior officer of the facility, 

resolve any conflicts of interest that may 

arise;

(iv) be responsible for establishing and 

administering the policies and procedures 

required to be established pursuant to this 

section;

(v) ensure compliance with this chapter and 

the rules and regulations issued under this 

chapter, including rules prescribed by the 

Commission pursuant to this section; and 

(vi)establish procedures for the remediation 

of noncompliance issues found during 

compliance office reviews, look backs, 

internal or external audit findings, 

self-reported errors, or through validated 

complaints.

(C) Requirements for procedures In 

establishing procedures under 

subparagraph (B)(vi), the chief compliance 

officer shall design the procedures to 

establish the handling, management 

response, remediation, retesting, and closing 

of noncompliance issues.

(D) Annual reports

(i) In general

procedures, and the CCO will prepare and file 

annual compliance reports with the Commission.

The Governance Policy provides that the 

Compliance Function’s duties include, but are not 

limited to: overseeing and reviewing iSwap Euro’s 

compliance with section 5h of the CEA and any 

related rules adopted by the Commission; in 

consultation with the Board, resolving any 

conflicts of interest that may arise; establishing 

and administering written policies and procedures 

reasonably designed to prevent violation of the 

CEA and any rules adopted by the Commission; 

taking reasonable steps to demonstrate 

compliance with the CEA and Commission 

Regulations relating to agreements, contracts, or 

transactions, and with Commission Regulations 

under section 5h of the CEA; establishing 

procedures for the remediation of noncompliance 

issues identified by the Compliance Function 

through a compliance office review, look-back, 

internal or external audit finding, self-reported 

error, or validated complaint; establishing and 

following appropriate procedures for handling, 

management response, remediation, retesting, 

and closing of noncompliance issues; establishing 

a compliance manual designed to promote 

compliance with applicable laws, rules and 

regulations and administering a written code of 

ethics designed to prevent ethical violations and 

to promote honesty and ethical conduct; 

supervising iSwap Euro’s self-regulatory program 

with respect to trade practice surveillance, market 

surveillance, real time market monitoring, 

compliance with audit trail requirements, 
22

In accordance with rules prescribed by the 

Commission, the chief compliance officer 

shall annually prepare and sign a report that 

contains a description of—

(I) the compliance of the swap execution 

facility with this chapter; and

(II) the policies and procedures, including the 

code of ethics and conflict of interest policies, 

of the swap execution facility. 

(ii) Requirements

The chief compliance officer shall—

(I) submit each report described in clause (i) 

with the appropriate financial report of the 

swap execution facility that is required to be 

submitted to the Commission pursuant to this 

section; and

(II) include in the report a certification that, 

under penalty of law, the report is accurate 

and complete.

enforcement and disciplinary proceedings, audits, 

examinations and other regulatory responsibilities 

with respect to Participants (including ensuring 

compliance with, if applicable, financial integrity, 

financial reporting, sales practice, recordkeeping, 

and other requirements); and supervising the 

effectiveness and sufficiency of any regulatory 

services provided to iSwap Euro by IMSL or any 

other registered futures association or other 

registered entity. 

The CCO will be responsible for all of the 

foregoing duties that relate to the CEA and the 

Commission’s Regulations. The CCO also 

prepares and files an annual compliance reports 

with the Commission as required by the CEA or 

Commission Regulations.