ISDA published its whitepaper (available here) in 2019 to inform market participants and regulators of the unique challenges that economic sanctions programs could present to over-the-counter (OTC) derivatives markets. Since that time, there has been a significant increase in the use of economic sanctions in furtherance of foreign policy goals in the US, the EU, the UK and beyond, which have raised issues for derivatives users. These measures include the US Chinese Military company sanctions of 2020 and 2021 as well as the sanctions programs implemented across the globe in response to Russia’s invasion and ongoing occupation of Ukrainian territory from February 2022. This paper examines the impact that sanctions programs have had on derivatives transactions since the publication of the 2019 whitepaper, considering the novel issues market participants have faced. It also assesses if sanctions programs have been implemented in a manner broadly consistent with principles set forth in the whitepaper, and proposes where additional action or guidance from sanctions authorities would further reduce uncertainty around the scope of the sanctions measures and the related relief and further reduce the potential adverse effects on non-sanctioned entities.
Documents (1) for Economic Sanctions Programs and Derivatives
Latest
ISDA In Review – August 2026
A compendium of links to new documents, research papers, press releases and comment letters published by ISDA in August 2026.
Remove Bureaucracy from Cross-margin Approvals
Cross-margining programs play a critical role in financial markets. By ensuring margin requirements more closely reflect the actual risk of a portfolio of products, they reduce liquidity strain and improve market efficiency, both of which will become even more important...
Joint Response on CCP Resolution
On September 7, ISDA and FIA responded to a Bank of England (BOE) discussion paper on central counterparty (CCP) resolution. The associations support greater clarity on valuation capabilities prior to a crisis scenario and the boundary between recovery and resolution,...
Expanding Legal Agreement Coverage in the CDM
This paper examines the recent extension of the Common Domain Model (CDM)1 to represent two of the most significant, and previously undeveloped, areas of its legal agreement model: umbrella agreements and contract amendments. Umbrella agreements are widely used to document...
