ICC guidance for banks on sanctions clauses

The International Chamber of Commerce Banking Commission published a guidance paper in 2014 on the use of sanctions clauses in trade finance-related instruments which are subject to ICC rules. The guidance focuses on the scope of sanctions clauses, potential issues in their application, and recommendations on best practices.

The ICC has issued an addendum (May 2020) to the paper following a reported resurgence in the use of such clauses. It provides guidance for banks on drafting, referencing sanctions regulations, and when not to use sanctions clauses. Both documents are in the Guidance section of this site.