Subject: S7-32-10: Webform Comments from Micah
From: Micah
Affiliation:

Aug. 4, 2023

Nefarious actors may exploit the lack of transparency in
swaps markets for various illicit activities due to the limited
oversight and reporting requirements. Some potential ways they might
use swaps include:

1. Insider Trading: Nefarious actors could use swaps to gain exposure
to a security without disclosing their positions publicly. This could
allow them to benefit from non-public information and engage in
insider trading without detection.

2. Market Manipulation: By using swaps, these actors can manipulate
the price of underlying securities or assets without attracting
attention, as their positions remain hidden from the public view. This
manipulation could impact the overall market sentiment and create an
unfair advantage for themselves.

3. Tax Evasion: Swaps can be structured in a way that helps
individuals or entities avoid taxes on capital gains or income. The
lack of transparency makes it challenging for tax authorities to track
such transactions effectively.

4. Money Laundering: Nefarious actors might use swaps to convert
illicit funds into seemingly legitimate investments or assets. The
complex and private nature of swaps can aid in disguising the origins
of money.

5. Risk Concentration: Large, unreported swap positions could lead to
significant risk concentration, potentially jeopardizing financial
stability and posing systemic risks.

6. Fraudulent Schemes: Swaps could be employed to facilitate
fraudulent schemes, where parties misrepresent the true nature of
transactions or the underlying assets involved.

7. Avoiding Regulatory Limits: Some financial regulations impose
limits on certain investment positions or activities. By using swaps,
nefarious actors can exceed these limits while concealing their actual
exposure.

8. Front-Running: Nefarious actors may use swaps to front-run other
market participants, taking advantage of their knowledge of large
pending transactions.

It's important to note that while swaps can be misused, they also
serve legitimate purposes, such as risk management and hedging
strategies. However, the lack of transparency in the swaps market can
provide a cover for unlawful activities, making it essential for
regulators to implement rules that enhance transparency and oversight
to mitigate these risks.