Community

The volume of long-dated FX swap/forwards trades is relatively minor and aren't generally to be of a materiality to be considered "systemically" important. This was one of the considerations in US Treasury thinking.

Moreover, the majority of the embedded risk in the trades is settlement risk, as studies have shown and clearing doesn't remedy settlement risk, only credit risk.

David

NDFs are not exempted from clearing and nor are cross currency swaps with the US Treasury decision.  Only FX Swaps [spot + forward] and Forwards are exempt, neither of which can be described at derivatives.

Hence, the trade structure you propose wouldn't be exempt.