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Central banks increasingly face indirect exposure to litigation risk via the institutions whose assets they buy or accept as collateral, a working paper published by the European Central Bank on Friday argues, in addition to direct legal challenges such as that applied to the National Bank of Belgium over its alleged climate failings.

The ECB’s CSPP, PEPP, general repurchase policies and collateral framework are especially vulnerable as sources of climate change litigation risk for the Eurosystem, author Javier Solana concludes, requiring financial supervisors to gain a better understanding of this type of litigation as a source of financial risk.