In both the US and EU, the Swap Market drafting and implementation of regulations is well advanced. Although the regulatory efforts in the US and the EU grew out of the same G-20 commitments and share many similarities, there are also important distinctions between the two. A comparison of how these two jurisdictions address the areas highlighted at the Pittsburgh G-20 – clearing, trading, reporting, and risk mitigation for uncleared swaps – follows. The report also discusses their differing approaches to the extraterritorial scope of their regulation, a critical issue not addressed by the G-20 accords.