Categories
Coffee and Regs

EMIR REFIT & Regulatory Harmonization

EMIR REFIT & Regulatory Harmonization

 
In this episode, our team of global transaction reporting experts, Alexis Wiazmitinoff and Nicklas Nilsson discuss changes coming to EMIR REFIT in 2022 and beyond. With the markets moving towards a harmonization of data elements across regulations, how will that provide regulators with a more complete and holistic view of OTC derivatives and improve operational efficiency for financial firms?
 

 

About Our Guest Speakers:

Alexis Wiazmitinoff is a Product Leader at CSS, responsible for leading the Global Transaction Reporting (GTR) solution. He is responsible for setting the GTR product roadmap and strategy. He guides the GTR product team during Sales/Pre-Sales engagements, product design/ delivery, thought leadership and takes part in client events. Alexis has 10 years of FinTech experience and a strong background working with traders, portfolio managers and front-to-back office personnel as part of core banking transformation projects on the continent and in the UK. Prior to joining CSS, Alexis product managed London Stock Exchange Group’s EMIR Trade Repository.

 
 
 



Nicklas Nilsson is a Regulatory Specialist at CSS concentrating on global transaction reporting, including SFTR, MiFIR and EMIR. Nicklas is currently in a cross-functional role covering the regulations from analysis to implementation. He has eight years of experience working in the finance industry, including operational experience in fund reporting and regulatory implementation. Prior to joining CSS, Nicklas held positions at Swedbank, SEB and Wahlstedt Sageryd.

 
 

Categories
Compliance Kitchen

FinCen Priorities


The Financial Crimes Enforcement Network (FINCEN) issued a policy on government-wide priorities (“Priorities”) for anti-money laundering (AML) and countering the financing of terrorism (CFT).  The Priorities identify and describe the most significant AML/CFT threats that the US is facing – the Kitchen is there to take a closer look at what goes into this recipe.

Categories
Innovation in Compliance

The Groundbreaking Guide to Third-Party & Supply Chain Risk Management: How Exiger’s TRADES Framework Revolutionizes TPRM & SCRM in 2021 and Beyond-Part 1, T for Transparency


Welcome to a special six-part podcast series, sponsored by Exiger, on the TRADES Framework, a conceptual, strategic and practical guide for Third-Party and Supply Chain Risk Management designed by Exiger to help organizations achieve supply chain resiliency and optimize risk management at any phase of maturity. Exiger was founded to fight financial crime, fraud and terrorist financing by introducing technology-enabled solutions to the market’s biggest supply chain, risk, investigation, litigation, and compliance challenges. A global authority on risk and compliance, Exiger serves the world’s largest banks, Fortune 1000 companies and government agencies and regulators. In this first episode, we consider transparency with Skyler Chi and Tim Stone.
The TRADES Framework is an important evolution in a rapidly evolving ecosystem of third party and supply chain risk management. There are a wide variety of risks that could be in your Supply Chain, including both distributor risks and vendor risks. The urgency of establishing best practices in this area was driven home most forcefully during the Coronavirus pandemic as governments at all levels were trying to secure the vaccines, Personal Protective Equipment (PPE) and pharmaceuticals that were needed. There has also been legislative initiatives with such laws as  the German Supply Chain Act starting to gain momentum. Of course modern slavery issues that were talked about before as well and the ESG revolution.
Tim Stone related that “T is for “Transparency of Current State”. There are different levels of transparency. He focused on Entity Level where the goal is to identify the full third-party ecosystem. Another way to think about it is “taking stock”. This stage involves illuminating your current state of affairs and identifying your vendor ecosystem.
The next step is how to build this initial tier of reliably accurate, validated, and de-duplicated entities that are mapped to business units, products, and use-case. You want as comprehensive a supplier and third-party ecosystem as possible. So how do you gain this transparency?
The first step is to identify, your internal supply data elements. You need to review your organization’s contracts and other paperwork, as well as engaging stakeholders across an organization in a fact-finding exercise, to arrive at a golden source of suppliers and vendors, and then mapping those entities to the products, business units, and use-cases across the organization. Next you should review external supply data elements.
“Transparency” is also about illuminating risk, which here means identifying the risks posed by the entities in a client’s supply chain. These risks are either inherent or imposed. Determining inherent risk, is where Exiger’s AI-powered due diligence platform, DDIQ, shines. DDIQ finds and categorizes risk information about focal companies and people. The platform searches hundreds of structured (e.g., watchlists) and unstructured (e.g., media) data sources and performs thousands of targeted queries – using proprietary search strings associated with different risk types and specific risky entities – to isolate and categorize risk information about a focal entity.
Next is imposed risk, which is “an aggregate view of a company’s upstream reliance on certain countries, such as China, for its receipt of goods. This extent of a higher risk country’s upstream footprint in a company’s supply chain is indicative of greater risk.” It also includes risk through downstream supply chain risk analysis to isolate where a company’s products are ultimately ending up.
Transparency also speaks to the governance and accountability associated with third-party (TP) and Supply Chain Risk Management (SCRM). There is a Strategic Level and a Program Level. As Skyler related you should create and document a TP&SCRM mission statement and purpose explanation, understand how mature your program is and create a baseline analysis of the program’s maturity. You then develop and maintain policies and procedures, which provide guidance and determine the right risk-area stakeholders and governance forums.
From this point, you should work to determine communication and workflows to operate the TP&SCRM program. This can be done through several steps, including data sourcing and right-sized technology aligned to the TRADES framework to ensure a single source of truth for each third party, supply chain, and overall program; continuous evaluation and improvements of the framework and periodic refreshes or reviews to assess industry/risk changes and best practices. Finally, it would lead to the creation of principles and guidance to help company stakeholders take risk-related decisions and actions.
Join us in our next episode, where we discuss the Risk Methodology with Theresa Campobasso and Matt Hayden.
Resources
Exiger TRADES Framework
Exiger Website
Skyler Chi
Tim Stone

Categories
The Ethics Experts

Episode 070 – Benjamin Halpert

In this episode of The Ethics Experts, Nick welcomes Benjamin Halpert, head of ethics and compliance at Anheuser-Busch, to the show.

Categories
FCPA Compliance Report

Jason Mefford


In this Episode of the FCPA Compliance Report, I am joined by Jason Mefford, a top thought leader in internal controls. We discuss his podcast Jamming with Jason, his online academy cRisk Academy and a unified theory of risk management. Highlights include:

  1. Why he began his podcast.
  2. How professionals consume information and content in 2021.
  3. Why he founded cRisk Academy.
  4. Unified risk management.
  5. What’s new in internal controls.
  6. The current state of live music.

Resources 
Jason Mefford on LinkedIn
Jamming with Jason
cRisk Academy

Categories
Daily Compliance News

July 19, 2021 the Speed v. Perfection edition


In today’s edition of Daily Compliance News:

  • Wal-Mart tagged for $125 in discrimination suit. (NYT)
  • Speed v. Perfection in IT. (WSJ)
  • Texas RRC to consumers: it wasn’t natural gas (but it was). (Houston Chronicle)
  • Eliminate animal based meat in 15? Impossible foods CEO says yes. (WaPo)