The expanded and increasingly novel use of targeted economic sanctions programs in recent years has potential ramifications for the derivatives market and there has been limited and inconsistent guidance on how, if at all, sanctions programs are intended to impact derivatives. This paper examines unique aspects of derivatives transactions that can present issues in interpreting how sanctions programs should apply in the context of derivatives and analyses these issues in the context of recent sanctions program experiences. This paper also proposes eight principles for sanctions authorities to be cognizant of when introducing new sanctions programs or extending existing sanctions programs to ensure the continued safe operation of derivatives markets and minimize market disruption and economic consequences for non-sanctioned entities, without compromising foreign policy or national security goals, conferring any benefit on sanctioned entities or otherwise harming the objectives of any sanctions program.
Click on the attached PDF to read the full paper.
Documents (1) for Economic Sanctions Programs & Derivatives
Latest
ISDA AGM Studio: Emmanuel Geinoz and Eleanor Kelly
Five jurisdictions went live with revised derivatives reporting rules in 2024, with more to follow in 2025 and beyond, putting reporting teams under extreme pressure to implement accurately and on time to avoid regulatory penalties. Emmanuel Geinoz, market infrastructure and...
ISDA AGM Studio: Tyler Wellensiek, Stephen Berger
The first phase of the Securities and Exchange Commission’s Treasury clearing mandate will come into effect in December 2026 – a requirement that will have a significant impact on both US and non-US market participants. Tyler Wellensiek, ISDA board member...
ISDA AGM Studio: Jacques Vigner, BNP Paribas
Jacques Vigner, ISDA board member and chief strategic oversight officer for global markets at BNP Paribas, speaks with Mark Gheerbrant, global head of risk and capital at ISDA, on the key obstacles to a consistent, risk-appropriate capital framework and how to...
ISDA AGM Studio: Future Leaders in Derivatives
Following publication of the latest whitepaper from the ISDA Future Leaders in Derivatives (IFLD) program, Collateral and Liquidity Efficiency in the Derivatives Market: Navigating Risk in a Fragile Ecosystem, Joel Clark talks to IFLD participants Koen Ottenheijm, senior treasury and...