On 13 July 2018, the CSSF published a press release stressing its attention on the
accurate reporting of derivative transactions. This is relevant to
all parties within scope of the European Market Infrastructure
Regulation (EMIR), of which the CSSF is the supervisory authority.
The communication follows up questionnaires sent to banks in winter
2017 and letters sent individually to non-financial counterparties
in spring 2017 regarding EMIR reporting.
To put the press release into context, the latest updates to the
EMIR reporting framework entered into force on 1 November 2017.
They introduced inter alia new requirements for market
data which, in our experience, have caused some difficulties.
Specifically, standardised identifications have not always been
available, e.g. the Legal Entity Identifiers (LEI) of each
counterparty, the Unique Trade Identifier (UTI) of each
transaction, or the International Securities Identification Number
(ISIN) of the underlying asset. In
