On April 9, 2025, the Market Participants Division and the Division of Market Oversight of the CFTC jointly issued CFTC Letter No. 25-10 to clarify the Divisions’ views on the regulatory treatment of certain foreign exchange products. Specifically, the Staff Interpretation clarifies that (1) “Window FX Forward” transactions should be considered “foreign exchange forwards” exempt from the “swap” definition in the Commodity Exchange Act and (2) “package Spot FX Transactions” are not “swaps” or “foreign exchange swaps.”