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EMIR Trade Confirmation Compliance



Real Time

A data-driven approach to automation and regulatory compliance.

A global interest rate trading division had to prove European Markets Infrastructure Regulation (“EMIR”) 11 compliance on a rolling 24 hour basis to meet its timely confirmation requirements.

“financial and non-financial counterparties that enter into an OTC derivative contract not cleared by a CCP shall ensure…that appropriate procedures and arrangements are in place to measure, monitor and mitigate operational risk and counterparty credit risk, including at least: (a) the timely confirmation, where available, by electronic means, of the terms of the relevant OTC derivative contract…“

Industry: Investment Banking


Data in Real Time

The Bank had tens of thousands of trades and trade amendments each day and five different versions of its primary trading system. It wanted to track trade confirmation in “real time” showing the last 24 hours on an hourly basis.

Complex Data Landscape

Trade life cycle events including novations, amendments and cancellations also had to be addressed.

Fragmented Technology

Direct access to the primary systems was not possible, but the system emitted an xml message for every trade life cycle event.

No Visualisation & Limited Insights

There was no single view dashboard that could allow them to drill down to different desks, regions and trade types across a number of compliance KPIs.

Data Solution

Creating the system components

Calimere Point created a system with four main components:

  1. 1 real time xml receiver, aggregator and organiser
  2. xml data extraction
  3. xml process and join
  4. Trade lifecycle & KPI calculations
  5. A dynamic Dashboard

Project Approach

Like many Calimere Point projects, this Data Solution was driven by data and high-level requirements. Our experience and flexible iterative data tools were key to give rapid, accurate delivery as we could react to the data itself.

So where the user advised “confirmation_time – trade_time,” after examining the data we could argue, with evidence, that it should be “confirmation_time – audit_trade_time” without ever mentioning the words “change request.“

Trade life cycle events made life more complicated as rules had to be agreed for events such as “Trade -> Amend -> Amend -> Novate”

Each xml message had to identify and join to previous versions so the whole life cycle could be assembled, which became more interesting when trade Id's were amended.


Our team worked with the client’s market operations team to iteratively design, develop and implement a robust solution fast by leveraging data analytics and visualisation technologies.

The Dashboard

A dynamic dashboard was created that allowed drill down to different desks, regions and trade types across a number of compliance KPIs. It was accessible globally and refreshed every hour to show compliance status of he last 24 hours and detail of any non-compliant trades regardless of trade date.

A robust and repeatable framework - delivered fast.

Deep Industry Expertise

The combination of financial markets and data analytics expertise allowed our client to deliver a robust and repeatable solution to meet an extremely tight regulatory deadline.

Data-rich Analytics Dashboard

In addition to meeting the regulatory requirements, our solution went further by providing senior operations management with a dashboard displaying a rich set of historical OTC confirmation information.

This allowed them to plan, implement and monitor process improvements to establish more robust confirmation delivery to the Interest Rate Trading business.

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