UK FCA levels the London vs. New York FX playing field | Risk article
According to this Risk article, it would seem that the UK's Financial Conduct Authority has lined up with US regulators to give FX fowards (and presumably swaps) an exemption from EMIR reporting for UK located financial firms. FCA CEO Martin Wheatley
EMIR exemption as a whole: For now this applies to TR reporting only but the inference is that FCA has effectively excluded FX forwards and swaps from the EMIR definition of derivatives as a whole so would exclude them from ESMA clearing and other regulations too for UK located financial firms if the trade is with another firm which is in the UK or is not in EU / Switzerland.
FX clearing doesn't work yet anyway: since clearing for FX forwards and swaps doesn't yet work because of the lack of agreement of an approach between CCPs and CLS (the FX settlement netting platform) this step at least heads off for UK financial firms an obvious crunch where those products cannot be mandated to clear by regulators.
Non-UK firms: geographically, I presume this applies also to non-EU firms with operations in London too but no doubt discussion is required to figure out how it applies to the London located entities of say French, German, Swiss banks among others.
I was wondering how this conundrum might get resolved. No doubt more fun and games before Europe as a whole gets to a consensus on FX derivatives....