Over the past few decades, US and other financial regulators have had to think more and more about their regulations not just from a domestic standpoint, but from a global perspective as well.  One prime example is the US Securities and Exchange Commission, whose regulatory mandate has been broadened by the Dodd-Frank Act to include regulation of certain kinds of over the counter (OTC) derivatives.  Virtually unregulated previously, OTC derivative trading is a global phenomenon wherein firms from all over the world write and trade complex financial instruments for a variety of reasons from hedging and liquidity purposes, to more speculative uses.  The Dodd-Frank mandate to the SEC to regulate OTC derivatives is unambiguous: bring security based swaps into some sort of central clearing regime, and make the individual transactions of major swap participants and dealers more transparent. In the case of security based swaps, the SEC has struggled greatly with the cross-border implications of its mandate.  How should the new regulatory regime for US swaps apply when a transaction occurs partially within and partially outside the US?   Last week, the SEC took a stab at this question by proposing rules and interpretive guidance applicable to certain market intermediaries, participants, clearing agencies, data repositories, and trade execution facilities that are involved in cross-border transactions of security-based swaps.