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Case Study

EMIR Trade Reporting for UK-based Global Asset Manager

The client

UK Based Global Asset Manager

The work

Our client engaged us to conduct an end to end review of their European Market Infrastructure Regulation on derivatives, central counterparties and trade repositories (EMIR) Trade Reporting function and governance.

The existing operating model didn’t deliver the submissions for the full universe of their derivatives trading to the trade repository, and the client was struggling to accurately identify what hadn’t been reported, how to
remediate the failures, and how to gauge their level of regulatory compliance.

No one person or team could describe the whole operating model and as a result, no one had the comprehensive oversight to be able to analyse and identify the flaws in the operating model.


The assignment involved performing an independent review of the infrastructure, operating models, technology, policies, processes, roles and responsibilities and governance.

How we helped

We interviewed all stakeholders and participants individually to determine their role in the process and their opinion of its effectiveness. All existing policy and process documentation were reviewed and the gaps
identified. Data architects and IT developers were interviewed and we pieced together a comprehensive dataflow map to assist the client in identifying where data drop outs were occurring.

We analysed both the governance over the process and the roles and responsibilities and made recommendations for comprehensive changes.


By the end of the assignment we were able to present a Key Findings document and a Risks and Controls Matrix to senior stakeholders which listed all of the inherent risks involved in the process, the mitigating controls, how effective the client was in executing those controls and recommendations on remedial actions.

Value added

Xcina’s operational, technical and regulatory knowledge skills, and experience enabled us to provide a completely independent assessment of the issues in the client’s end to end operating model, bringing into sharp
focus key themes for senior management, providing them with a platform to implement a robust process.

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