ICAP Global Derivatives Limited 

2 Broadgate 

London 

United Kingdom 

EC2M 7UR 

March 1, 2022 

Submitted via CFTC Portal 

Mr. Christopher J. Kirkpatrick 

Office of the Secretariat 

Commodity Futures Trading Commission 

Three Lafayette Centre 

1155 21st Street, N.W. 

Washington, D.C. 20581 

Re: ICAP Global Derivatives Limited – Regulation 40.6(a) Rule Certification – 

Notification of Amendments to Compliance Manual (IGDL-2022-R-1)

Dear Mr. Kirkpatrick: 

Pursuant to Section 5c(c) of the Commodity Exchange Act, as amended (the “Act”), and Section 

40.6(a) of the regulations of the Commodity Futures Trading Commission (the “Commission” or 

“CFTC”), ICAP Global Derivatives Limited (“IGDL”), a registered swap execution facility, 

hereby notifies the Commission that it is self-certifying amendments to its Compliance Manual, 

as described more fully in the Exhibits attached hereto. The intended date of implementation of 

the amendments is March 15, 2022. 

Pursuant to Commission Regulation 40.6, this submission includes: 

(i) A concise explanation and analysis of the amendments to the Compliance Manual and 

their compliance with applicable provisions of the Act and the Commission 

regulations thereunder, attached as Confidential Exhibit A; 

(ii) A clean copy of the amended Compliance Manual, attached as Confidential Exhibit 

B; and 

(iii) A copy of the Compliance Manual marked to show changes to the currently effective 

version, attached as Confidential Exhibit C. 

IGDL hereby certifies that the amendments comply with the requirements of the Act and 

Commission regulations thereunder. 
Mr. Christopher J. Kirkpatrick 

March 1, 2022 

Page 2 

IGDL is separately filing with the Assistant Secretary of the Commission for FOI, Privacy and 

Sunshine Acts Compliance, pursuant to Commission Regulation 145.9, a petition for confidential 

treatment of Confidential Exhibits A, B, and C (the “FOIA Confidential Treatment Request”) on 

the grounds that disclosure would reveal confidential commercial and financial information. A 

copy of the FOIA Confidential Treatment Request is included with this submission. 

IGDL is not aware of any substantive opposing views expressed with respect to this filing and 

certifies that, concurrent with this filing, a copy of this submission was posted on IGDL’s 

website. 

Please contact Brian D. Donnelly, Chief Compliance Officer, at (201) 984-6956 or by email at 

bddonnelly@tullettprebon.com with any questions regarding this matter. 

Very truly yours, 

ICAP Global Derivatives Limited 

By: __________________________ 

Name: Brian D. Donnelly 

Title: Chief Compliance Officer 

Date: March 1, 2022 

Enclosures 

cc: CFTC Division of Market Oversight (dmosubmissions@cftc.gov) 

Nancy Markowitz, CFTC (nmarkowitz@cftc.gov) 
Mr. Christopher J. Kirkpatrick 

March 1, 2022 

Confidential Exhibit A

Explanation of Amended Compliance Manual 

[FOIA Confidential Treatment Requested]

 
Mr. Christopher J. Kirkpatrick 

March 1, 2022 

Confidential Exhibit B

IGDL Compliance Manual 

(Clean Version) 

[FOIA Confidential Treatment Requested] 

 
Mr. Christopher J. Kirkpatrick 

March 1, 2022 

Confidential Exhibit C

IGDL Compliance Manual 

(Marked Version) 

[FOIA Confidential Treatment Requested]