FX settlement risk: paying one currency without receiving the other

Every currency trade has two payments, one in each currency, and they often settle in different systems at different hours. FX settlement risk is the chance that one side pays and the other never does, so the full principal is lost. Its other name comes from Cologne: Herstatt risk, after the bank whose closure in 1974 showed how it works.

Frankfurt and New York wall clocks above a foreign-exchange settlement sheet

The Herstatt case

On June 26, 1974 the German supervisor withdrew the license of Bankhaus Herstatt, then the 35th largest bank in the country. It acted after the close of business in Germany, while the US business day was still running, as the Bank of England's Bank Underground blog recounts from its archives. Counterparties had already paid Deutsche Mark to Herstatt and were waiting for the dollar leg in New York, which never came. Banks in other countries then held back their own payments, and the New York Clearing House introduced a recall procedure on July 1, 1974.

How CLS and payment versus payment remove it

Payment versus payment (PvP) settles both legs at once, or neither. CLS is the main PvP service for currency trades: CLS Bank began operating on September 9, 2002, settles 18 currencies, and is overseen by the Federal Reserve. Members pay in their net amounts during a five-hour window when the payment systems of all CLS currencies are open, and CLS pays out only when both legs are there. Netting reduces the cash members have to fund by about 96 percent.

Other PvP arrangements exist for currencies outside CLS. SIX, for example, describes FXS, a PvP system authorized by the Banco de España for euro area banks.

How much is still at risk

The BIS measured settlement for the first time in its 2025 Triennial Survey. Its analysis in the June 2026 Quarterly Review counts more than 14 trillion dollars of FX obligations settled on an average day in April 2025. About 36 percent settled PvP and 54 percent through methods that reduce the risk without removing it, such as netting and settlement within a banking group. About 10 percent, more than 1.4 trillion dollars a day, settled gross and bilaterally with the full principal at risk. Around a quarter of that could have used PvP and did not; for most of the rest the counterparty had no PvP access or the currency pair was not eligible.

Settlement risk beyond the big banks

The remaining risk sits with smaller banks, non-bank financial firms and currencies outside CLS. The BIS authors point to wider PvP access for non-banks and more currencies as the next steps. Tokenized settlement promises the same atomic exchange on a shared ledger, which the pages on wholesale CBDC and settlement finality discuss, together with the legal question of when a payment counts as final.

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What is Herstatt risk?

Another name for FX settlement risk: the risk that a bank pays the currency it sold and does not receive the currency it bought, because the counterparty fails between the two payments. It is named after Bankhaus Herstatt in Cologne, closed on June 26, 1974.

How does CLS remove settlement risk?

CLS settles both legs of a currency trade at the same moment on its own books and pays out only when both sides have paid in. If one side does not pay, the other side gets its money back.

Why is not all FX settled payment versus payment?

According to the BIS, most trades settled with full risk involve a counterparty without PvP access or a currency or trade type that the PvP services do not cover. A quarter could have used PvP and were settled gross anyway.

FX settlement risk and Finance Loop

Finance Loop is the meeting place in Frankfurt for the treasury, risk and market infrastructure people who deal with settlement every day. Finance Loop has partnered with the Crypto Assets Conference of Frankfurt School and Deutsche Börse Group, where market infrastructure and tokenized settlement are on the program.

Finance Loop is a professional network and has the goal of driving the adoption of emerging technologies in finance, such as AI, digital payments, cloud and blockchain solutions. Finance Loop helps its members build skills and personal networks in these fields: Investment & Digital Assets, Payments & Digital Money, Digital Infrastructure & Sovereignty, and Risk & Compliance.

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