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.

S&P Global Selected as DC Administrator

ISDA and the Credit Derivatives Governance Committee have announced that S&P Global Market Intelligence has been selected as the administrator for the Credit Derivatives Determinations Committees (DCs). The announcement follows an invitation to tender in November 2025. The DC administrator...

Supporting ISDA SIMM Adoption in Australia

Derivatives have become a critical tool for Australia’s massive superannuation sector, as funds look to manage the risks associated with their expanding offshore investments. The use of derivatives brings real risk management benefits, but it also means funds need to...