Following the G20 commitment to implement measures to increase transparency and reduce counterparty credit risk and operational risk in the derivative markets, the European Commission introduced a new EU Regulation on over-the-counter derivatives (OTC), central counterparties (CCPs) and trade repositories (also known as the European Market Infrastructure Regulation, EMIR). In addition, the European Parliament and the European Council have adopted a directive and regulation replacing the Markets in Financial Instruments Directive (known as MiFID II). Simultaneously, in the United States, the Dodd-Frank Wall Street Reform and Consumer Protection Act (Dodd-Frank) seeks to deal with similar risk issues in relation to derivatives markets. The document shows a detailed comparison of the regulatory system.[…]