Comments recently from ESMA’s (European securities regulator) chief Steven Maijoor indicated that the Europeans will apply margin requirements to FX trades (presumably including FX forwards) in Europe, setting up a potentially notable difference between the EU and US approaches. The article states: “Maijoor noted bilateral collateralization laws for affecting FX derivatives would be present in European regulations but not U.S. laws, according to the media outlet.” Majioor stated, “The real issue for FX derivatives that only a few have spotted is not the clearing obligation, but bilateral [collateralization]. The problem of international inconsistency and regulatory arbitrage is much more serious for margin for contracts that are not centrally cleared.”