Unwelcome Intrusion: Reckoning with the Impact of Economic Sanctions on Derivatives Transactions | Cadwalader, Wickersham & Taft LLP
I. A Growing Risk The United States, along with the United Kingdom and European Union, has increasingly wielded economic sanctions against major commercial actors and financial transactions, sometimes roiling global markets in the process. It is now common for sanctions to target not only rogue regimes, terrorists, and drug traffickers, but also major corporations that are deeply integrated into international financial markets – including derivatives markets. For evidence of this trend, one need look no further than the November 12, 2020 Executive Order (“E.O.”) “on Addressing the Thr...