ICC trade finance rules in the context of the Middle East conflict

Scott Sanchon, Trade Treasury Payments (TTP)

If your business uses letters of credit, bank guarantees, or documentary collections, it is essential to understand how the ongoing conflict in the Middle East, which began on 28 February 2026, could impact your trade finance operations. 

On April 8, 2026, the International Chamber of Commerce (ICC) published a document guiding the impact of the conflict in the Middle East on trade finance operations. This guide explains what you need to know from the ICC report, which aims to recall existing guidance under the ICC rules and framework. 

The rules have not changed

ICC’s trade finance rules, including UCP 600 (letters of credit), URD 758 (bank guarantees), URC 522 (documentary collections), and ISP98 (standby letters of credit), continue to apply as normal. 

The ongoing conflicts could create practical challenges, including sanctions, insurance complications, supply chain disruptions, and the physical handling of trade documents. This ICC guide walks you through the rules already in place to address those disruptions. 

What if documents get delayed or lost? During the conflict, sometimes documents sent between banks go missing or arrive late. Under provisions such as UCP 600 article 35, URDG 758 sub-article 28(a), and URC 522 sub-article 14(a), banks are not held responsible if documents are delayed, lost, or damaged during transit. 

In other words, if documents do not arrive on time due to circumstances beyond the bank’s control, the bank is protected. 

Force majeure

Force majeure is a term included in many contracts referring to extraordinary events that make it impossible to fulfil obligations, such as war, a global pandemic, or natural disasters.

According to ICC rules, this clause will apply only when the bank itself is unable to operate. A bank cannot request force majeure simply because the broader environment has become more difficult.

For example, if a bank’s operations are disrupted, that is a matter for the underlying contract between the bank and its counterparties, not for ICC rules.  

Though, of course, there may be situations where traditional methods cannot deliver original paper documents. ICC rules allow parties to agree on alternative arrangements, such as scanned or electronic copies of original documents or other agreed methods of presentation, which are deemed practical in the circumstances.

In practice, an alternative arrangement requires a mutual decision to move forward with the process.

Using eUCP or eURC for electronic presentation

If you and your counterparty want to process everything digitally, the ICC has suggested considering using electronic supplements, including eUCP (for letters of credit) and eURC (for documentary collections). 

These supplements provide clear rules of electronic records. These can be incorporated into your trade finance instructions if both parties agree. ICC, through its Global Banking Commission, will continue to closely monitor developments. If circumstances arise that materially affect the processes, further guidance may be considered. 

For example, if you are using URDG 758 for bank guarantees, there is no need for a separate supplement. 

In the meantime, ICC suggests that everyone continue applying the relevant ICC rules in the usual manner. However, ICC recommends keeping a close eye on developments, particularly if transactions involve parties in the affected region.

Should the conflict escalate to the point where normal processing is no longer possible, the ICC’s Global Banking Commission will issue further guidance.