It is important that EMIR address intragroup transactions in a way that is (a) proportionate and appropriate for the real level of risk involved (taking into account that the client–facing transactions will be either cleared or bilaterally margined (depending on whether the contract is clearing-eligible) and these are internal group back-to-back transactions, which do not increase inter-connectedness in the financial system) and (b) internationally coherent, in such a way that European and US (and other) financial groups can continue to compete for clients on a safe basis, and ensuring that risk management is not compartmentalised geographically (EMIR should not promote trade barriers).