How Does the Regulation of CCPs Differ between the US (CFTC) and Europe (EMIR)?

In the US, the CFTC regulates Derivatives Clearing Organizations (DCOs), which are the equivalent of CCPs, primarily through the Dodd-Frank Act. In Europe, the European Market Infrastructure Regulation (EMIR) sets the rules for CCPs.

Both aim to increase safety and stability through mandatory clearing, robust risk management, and capital requirements, but their specific legal and operational frameworks differ.