Skip to content

Risk-mitigating actions

For OTC derivatives which are not cleared, EMIR stipulates that certain risk-mitigating actions shall be taken.

The following applies for both financial and non-financial counterparties:

  • Exchange of confirmation with the counterparty – in writing or electronically
  • Execution of portfolio reconciliation with the counterparty
  • Agreement on routines with the counterparty for dispute resolution relating to trading in OTC derivatives
  • Implementation of routines for compression of outstanding OTC derivatives, if exceeding 500 contracts with the same counterparty

Companies that exceed the clearing threshold, as well as financial counterparties, shall also conduct daily valuation of outstanding OTC contracts and daily exchange of collateral. 


Swedbank will send a confirmation to you as a corporate client for each OTC-derivative transaction that you conduct. You will need to verify each confirmation by signing it and returning it to Swedbank via e-mail, the internet bank or fax, no later than on the first banking day after the date of transaction (for companies that exceed the clearing threshold) or on the second banking day after the date of transaction (for companies that are below the threshold).

Portfolio reconciliation

Companies must reconcile outstanding OTC-derivative contracts with their counterparties. Depending on the number of outstanding transactions that a company has with Swedbank, Swedbank will send statements regarding open positions on a yearly basis or on a quarterly basis. Thereafter, the company will need to review the statement and either confirm the information in it, or inform Swedbank that the information is not correct.

Dispute resolution

Companies that trade in OTC derivatives must conclude agreements with their counterparties stipulating routines for dispute resolution.

Portfolio compression

Companies that have more than 500 contracts with the same counterparty must implement routines for compression of outstanding OTC-derivatives.