The IOSCO Final Report on Pre-Hedging: Is This the Final Word?

February 27, 2026

Cleary Gottlieb partner Ferdisha Snagg and associate Noah D’Aeth co-authored the article, “The IOSCO Final Report on Pre-Hedging: Is This the Final Word?” published in Butterworths Journal of International Banking and Financial Law.

Ferdisha and Noah examined the IOSCO’s revised definition of pre-hedging and its ten recommendations addressing conduct risks, how the framework will be applied in practice, and whether it can promote convergence across jurisdictions.

Read the article (subscription required).