Risk have a good article highlighting how a non-US firm with a branch in the US, must comply with a whole bunch of regulations for the Volker Rule.

Original story here (subscription required)

Summary:

Banks will have to document the scope of every trader’s activities and have chief executive sign off on Volcker compliance regime

Non-US banks that have a US branch will be allowed to engage in proprietary trading under the proposed Volcker rule text – but the exemption comes at the cost of a sprawling compliance regime that would, among other things, require each bank to provide US regulators with a list of every trader in the organisation, documenting the scope of his or her trading activity. Foreign banks are struggling to digest the implications.

“We were stunned when the rule came out. We had no idea it would contain this kind of overreach. The obligations that will be placed on entities based overseas will be overly burdensome to say the least, and I’m not sure how we are going to comply with it,” says one lobbyist at a European bank in Washington, DC.