Chambers Global Practice Guides: Derivatives 2026

Our partner Pablo Perezalonso and associate Isabel Ortiz Monasterio, together with former associate Alejandro Mosqueda, contributed to the Mexico “Trends and Developments” chapter of Chambers Global Practice Guide: Derivatives 2026.

The chapter examines the evolution of Banco de México’s regulatory approach to credit derivatives, including Credit Default Swaps (CDS), Total Return Swaps (TRS), and Credit-Linked Notes (CLNs), following years of regulatory caution after the 2008 financial crisis.

Among the key developments analyzed are:

• The expansion of counterparties authorized to trade credit derivatives under Circular 6/2023
• New participation rules for banks, broker-dealers, investment funds, insurers, and SIEFOREs
• Full-funding requirements applicable to certain Total Return Swaps
• The formal recognition of insurance companies and broker-dealers as market participants
• The remaining regulatory inconsistency affecting SIEFORE participation

For banks, insurers, SIEFOREs, and other institutional investors affected by these changes, the new framework requires a careful review of eligible underlyings, funding requirements, and remaining regulatory inconsistencies before entering into credit derivative transactions. 

We invite you to read the full chapter for more information on this topic.