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Noah D’Aeth

Associate
Noah D’Aeth is an associate at Cleary Gottlieb Steen & Hamilton LLP, specialising in UK financial services regulation. Email: ndaeth@cgsh.com

Articles by author

The IOSCO Final Report on pre-hedging: is this the final word?

In November 2025, the International Organization of Securities Commissions (IOSCO) published its Pre-Hedging Final Report (the Final Report), concluding a review that began with a November 2024 Consultation Report (the Consultation Report) and built on earlier regulatory and industry work.

27 FEB 2026

Loan participations: conflict-of-laws challenges under English and New York law

This article examines the divergent treatment of loan participations under English and New York law, focussing on how each jurisdiction characterises the legal relationship between grantor and participant. It explores the conflict-of-laws challenges that arise when structuring cross-border financing transactions in which the underlying loan and participation agreement may be governed by different legal systems.

22 NOV 2025