Economic Sanctions Programs and Derivatives

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.

Building Markets, Creating Opportunity

Deep and liquid derivatives markets are fundamental to the development of well-functioning financial markets and healthy economies. They support lending, investment and financial stability, creating the certainty needed for economic growth. But strong derivatives markets do not emerge by chance....

Key Trends in OTC Derivatives Market H2 2025

The latest data from the Bank for International Settlements over-the-counter (OTC) derivatives statistics shows an increase in notional outstanding of OTC derivatives during the second half of 2025 compared to the same period in 2024. Notional outstanding rose across all...