EMIR Risk Mitigation Techniques - Less Than One Month To Evidence Compliance

30 April 2014: this is the deadline that the Financial Conduct Authority (FCA) has set for firms to demonstrate compliance with the Risk Mitigation Techniques requirements for non-centrally cleared derivatives set out in the European Markets Infrastructure Regulation (EMIR). This leaves firms just over two weeks not only to ensure that they have processes and controls in place to comply fully, but also that those processes and controls are documented to a standard that will satisfy the regulator. Many firms may be failing to meet one or even both of those targets.

The FCA will fully integrate these new requirements into its supervisory activities through its Firm Systemic Framework. Its supervision of EMIR compliance will focus initially on the Risk Mitigation Techniques which came into force in March and September 2013; the regulator expected firms that were unable to comply with these requirements immediately to have a detailed and realistic plan to achieve