SOTUS

Solely Outside of the United States. The “SOTUS exception” of the Volcker Rule’s trading restrictions permits a foreign banking entity to engage in proprietary trading if the parties to the trade and people involved in the trade are located outside the United States, and limited trading with or through a US entity is permitted under very limited circumstances. The SOTUS exception permits a foreign banking entity to acquire or retain an ownership interest in, or to sponsor, a covered fund “solely outside of the United States” if certain conditions are satisfied.