COUNTERPARTY FILE · last re-checked 2026-09
CLS Bank (CLSSettlement / CLSNet) — institutional liquidity provider
This record reflects ongoing operational complexities and variances in reported figures.
Licence, read literally
| Regulator | Licence number | Jurisdiction | Tier | Source |
|---|---|---|---|---|
| US Federal Reserve (Edge Act corporation; designated financial market utility under Dodd-Frank Title VIII) | not verified | US | tier-1 | open source ↗ |
Tier classification follows the same scale as the retail register: tier-2 means real supervision and client-money segregation, without an investor compensation scheme — never misread it as tier-1 protection.
Residuals a counterparty carries
Unverified daily settlement figure
CLS's own published figure of USD8.0 trillion settled daily is not independently audited.
Source: cls-group.com/products/settlement/clssettlement
Inconsistent settlement member count
Settlement member count varies between sources, listing 60+ members per CLS and 70 per Bundesbank.
Source: bundesbank.de/en/tasks/payment-systems/oversight/continuous-linked-settlement-626502
The claims ledger
Claims specific enough to be falsified — and the ones that remain the venue's own measurement.
Testable claims
- CLS's own CLSSettlement page states 'Each day we settle over USD8.0 trillion of payments in 18 of the most actively traded currencies globally' (cls-group.com/products/settlement/clssettlement)
- Own corporate-governance page: 'CLS Bank International (CLS Bank) is an Edge Act corporation, which is a limited purpose institution regulated by the US Federal Reserve', located in New York, maintaining a central bank account for each of the 18 eligible currencies (cls-group.com/about/corporate-governance)
- The US Federal Reserve's own page: 'CLS is chartered by the Board as an Edge corporation under Section 25A of the Federal Reserve Act... The Board is the Supervisory Agency for CLS under Title VIII of the Dodd-Frank Act... as an Edge corporation, CLS Bank is supervised and regulated as a bank by the Federal Reserve' (federalreserve.gov/paymentsystems/designated_fmu_about.htm)
- Bundesbank oversight page: CLS began operations on 9 September 2002 with 39 settlement members in 7 currencies; today settles for 70 institutions (settlement members) and over 35,000 third parties in 18 currencies (bundesbank.de/en/tasks/payment-systems/oversight/continuous-linked-settlement-626502)
Claims we cannot verify from outside
- USD8.0 trillion daily settled payments is CLS's own published figure, not independently audited
Perimeter and coverage
| Asset classes | Venues | Connectivity | Clients accepted | Explicitly refused |
|---|---|---|---|---|
| FX settlement (PvP), OTC credit derivatives settlement (DTCC TIW), CLSNet trade notification/netting | CLSSettlement (multicurrency PvP settlement system), CLSNet (bilateral/multilateral netting and trade notification) | SWIFT, Direct connections to RTGS systems (Fedwire, T2, CHAPS, SIC, RITS, KRONOS, CHATS, BOJ-NET and others), CLS third-party service via settlement members | Over 60 settlement members (banks), Over 18,000 third-party users |
A firm that publishes its own negative space — who it refuses, where it is not licensed — is materially easier to diligence than one that doesn't. The refusal list is treated here as disclosure, not as a defect.