ICC Banking Commission
Use of Sanctions Clauses in Trade Finance
Following the escalation of sanctions on Russian businesses, individuals and financial institutions over the past few days, ICC has taken the decision to reissue the previous ICC guidance on the use of sanctions clauses in documentary credits in consolidated form.
To reiterate our core guidance:
Sanctions law and regulations are generally mandatory, and thus may override the ICC rules applicable to that instrument. As such, the addition of a clause, stating the bank’s commitment to respect such sanctions law or regulation applicable to it by law may be unnecessary and lead to confusion.