Short-Term and Long-Term Restricted Cash, Cash Equivalents, and Investments

12 Months Ended

Dec. 31, 2024

Cash and Cash Equivalents [Abstract]

Short-Term and Long-Term Restricted Cash, Cash Equivalents, and Investments

Short-Term and Long-Term Restricted Cash, Cash Equivalents and Investments

Our total restricted cash, cash equivalents and investments including short-term and long-term portions, consisted of the following (in millions):


	As of December 31,
	2024		2023
Restricted cash, cash equivalents and investments:
Short-term restricted cash, cash equivalents and investments:
ICE Futures Europe	$	125	$	100
ICE Clear Europe	755		730
CFTC Regulated Entities	290		292
Other Regulated Entities	56		79
Other	510		10
Total short-term restricted cash, cash equivalents and investments(1)	1,736		1,211
Long-term restricted cash, cash equivalents and investments:
ICE Clearing House Portion of the Guaranty Fund Contribution	370		340
Total long-term restricted cash, cash equivalents and investments(2)	370		340
Total restricted cash, cash equivalents and investments	$	2,106	$	1,551

(1) Included in the total short-term restricted cash, cash equivalents, and investments are certain investments that have maturities of greater than three months at the time of purchase and therefore are included in short-term restricted investments in the consolidated balance sheet. The total short-term restricted investments as of December 31, 2024 and 2023 was $594 million and $680 million, respectively.

(2) Included in the total long-term restricted cash, cash equivalents, and investments are certain investments that have maturities greater than three months at the time of purchase and therefore are included in Other non-current assets in the consolidated balance sheet. The total long-term restricted investments as of December 31, 2024 was $2 million. There were no long-term restricted investments as of December 31, 2023.

Short-Term Restricted Cash, Cash Equivalents and Investments

Our short-term restricted cash and cash equivalents and restricted short-term investments in the table above consist of the following:

•ICE Futures Europe: ICE Futures Europe operates as a U.K. Recognized Investment Exchange, and is required by the U.K. Financial Conduct Authority to maintain financial resources sufficient to properly perform its relevant functions equivalent to a minimum of six months of operating costs, subject to certain deductions.

•ICE Clear Europe: ICE Clear Europe operates as a U.K. Recognized Clearing House. As such, ICE Clear Europe is required by the BOE and the European Market Infrastructure Regulation, or EMIR, to restrict as cash, cash equivalents or investments in an amount to reflect an estimate of the capital required to wind down or restructure the activities of the clearing house, cover operational, legal and business risks and to reserve capital to meet credit, counterparty and market risks not covered by the members' margin and guaranty funds. As such, it is calculated taking into account the operating expenditures, revenues and credit exposures associated with the assets and investments. ICE Clear Europe, in addition to being regulated by the BOE, is also regulated by the CFTC as a U.S. Derivatives Clearing Organization, or DCO, and by the European Securities and Markets Authority, or ESMA, as a third-country central counterparty. The regulatory capital available to ICE Clear Europe, as described above, exceeds the CFTC requirements.

•CFTC Regulated Entities: Our CFTC regulated U.S. Designated Contract Market, or DCM, ICE Futures U.S., our CFTC regulated U.S. DCOs, ICE Clear U.S. and ICE Clear Credit, our CFTC regulated U.S. Swap Data Repository, or SDR, ICE Trade Vault, LLC, and our U.S. Swap Execution Facility, or SEF, ICE Swap Trade, are required to maintain financial resources including cash, in an amount that would cover certain operating costs for a one-year period, subject to certain deductions, to satisfy at least six months of such operating costs at all times. For our U.S. DCOs, ICE Clear U.S. and ICE Clear Credit, these amounts include voluntarily-held additional reserves consistent with the EMIR requirements to cover operational, legal and business risks and to reserve capital to meet credit, counterparty and market risks not covered by the member margin and guaranty funds. ICE Clear Credit is also regulated by the SEC as a clearing agency because it clears security-based swaps. In addition, ICE NGX is registered by the CFTC as a Foreign Board of Trade and a DCO and the CFTC requires ICE

NGX to maintain financial resources including cash, in an amount that would cover certain operating costs for a one-year period. ICE NGX is regulated by both the CFTC and the Alberta Securities Commission.

•Other Regulated Entities: Restricted cash on our various regulated entities and exchanges includes ICE Endex, ICE Benchmark Administration, ICE Clear Netherlands, ICE Futures Abu Dhabi, ICE Trade Vault Europe Limited, ICE Bonds Securities Corporation, among others.

•Other: Other restricted cash, cash equivalents and investments as of December 31, 2024 was primarily related to the new senior notes issued in May 2024 of which $500 million of the net proceeds has been invested and will be used to repay a portion of the aggregate principal amount of the senior notes maturing in May 2025.

Long-Term Restricted Cash, Cash Equivalents and Investments

Our long-term restricted cash, cash equivalents and investments in the table above consist of the following:

•ICE Clearing House Portion of the Guaranty Fund Contribution: Our clearing houses, other than ICE NGX, require each clearing member to make deposits to a fund known as the guaranty fund. We have a $15 million first-loss amount related to ICE NGX insurance and included in our contribution to its guaranty fund. ICE NGX has also set aside $30 million of its own capital that could be used for liquidity purposes in the event of a Contracting Party default. See Note 14 for additional information on the guaranty funds and our contributions of cash to our clearing houses' guaranty funds.