Regulatory Alerts2025-09-24
Circular Re. Trade Repository Reporting and Risk Mitigation Requirements for Over-the-Counter (OTC) Derivatives Contracts
The Saudi Central Bank (SAMA) has issued updated Trade Repository Reporting and Risk Mitigation Requirements for Over-the-Counter (OTC) Derivatives Contracts, mandating the use of a Unique Product Identifier (UPI) and establishing strict T+1 reporting timelines for all reportable transactions. The updated framework, effective 1 February 2026, supersedes Circular No. 42056371 and applies to all licensed banks in the Kingdom, requiring direct electronic reporting to an authorized Trade Repository Operator without outsourcing. Furthermore, Section B imposes comprehensive risk mitigation obligations—including trading relationship documentation, trade confirmation, valuation, portfolio reconciliation, compression, and dispute resolution—on banks executing non-centrally cleared OTC derivatives regardless of their notional amount or hedging status.