Page 18 - 期货和衍生品行业监管动态（2025年11月）

期货和衍生品行业监管动态

关键基础，并已发布了针对全球 90 个司法管辖区的净额结算法律意见。通过允

许交易对手方将其义务简化为一次性支付，净额结算大幅降低了信用风险。根据

国际清算银行数据，截至 2024 年底，全球衍生品合约的总市值为 17.6 万亿美元，

而且经法律认可的双边净额结算协议调整后的总信用风险敞口总额仅为 3.0 万亿

美元。

ISDA 净额结算法律意见可通过此链接获取。

https://www.isda.org/2025/11/03/isda-extends-saudi-arabia-netting-opinions/

ISDA Extends Saudi Arabia Netting Opinions (2025/11/3)

ISDA has extended its netting opinions for Saudi Arabia to cover regulations

published by the Capital Market Authority (CMA) earlier this year that recognize the

enforceability of close-out netting.

The CMA regulations were published in July, and follow similar rules published

by the Saudi Central Bank (SAMA) in February. The CMA regulations apply if at

least one party is a capital market institution supervised by the CMA, which includes

dealers and investment managers. Both the CMA and SAMA rules are closely based

on ISDA’s 2018 Model Netting Act.

ISDA published netting opinions under the SAMA regulations in June. Those

netting opinions – one under the ISDA Master Agreement and one for Islamic

derivatives under the ISDA/International Islamic Financial Market Tahawwut Master

Agreement – have now been extended to cover the CMA rules. Riyadh-based law firm

STAT was commissioned by ISDA to draft the netting opinions.

ISDA is also developing collateral opinions under both regulations, which will be

published before the end of the year.

“Thanks to this important step by CMA, ISDA’s netting opinions now make clear

that netting is enforceable for trades with any Saudi financial counterparty, whether an

investment manager supervised by the CMA or a bank regulated by SAMA. This is a

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