RegTech-dependent obligations are being baked into policy which presents firms an opportunity to comply with these new rules in better, faster and cheaper ways. Cloud, data and AI technology are moving fast and offer opportunities for RegTech innovation.


We are pleased to announce the first wave of confirmed firms, regulators and trade associations are participating in JWG’s 8th annual RegTech conference, ‘Getting real about RegTech 2024. Don’t miss this opportunity to join this premier global event which articulates the key challenges which RegTech can help overcome in 2024. Register here RegTech year 8 Regulators


JWG’s eighth annual conference will be the premier, global event for setting the 2024 RegTech agenda on 7 February in London. Join us to help shape the debate today. Register for 7 February 2024  About the JWG RegTech agenda Long recognised as the first, biggest and most professional public/private sector agenda debate, JWG is continuing


JWG’s 22 March 2023 Trading Compliance Seminar brought together an all-star cast of over 20 experts who discussed plans for the latest MiFID Review, Market Data changes, CTP, MAR, ESG data demands, MiCA and UK digital asset efforts. These experts did an outstanding job in putting regulatory demands into context and provide delegates with valuable


Winning the ESG data Marathon in 2023

Winning the ESG data Marathon in 2023 With the ever-increasing focus on ESG transparency from regulators and clients, firms are racing to meet the requirements needed to make their mark in the global marketplace. This race requires tens of thousands of market participants to produce data according to different standards. However, with a proper plan


Regulators are busy engineering sell-side and buy-side rule changes which will change the markets, customer and risk management obligations starting this year. JWG has analysed the global landscape and assembled 20+ all-stars at our *virtual* Trading Seminar to discuss our exclusive RegTech research on upcoming compliance challenges.  7 days left to get your Complimentary VIP


New UK Asset Management RegTech Drive

The UK’s second discussion paper of 2023 on the benefit of modern technology presents a great chance for the industry to engage on the future of TradFI and DeFi RegTech standards. Successful reference models can help shape the path for asset management. However, this is an enormous cultural and technical shift which will require broad


Trading RegTech all-stars announced

JWG’s sell-side and asset managers’ trading compliance radars are hot, and we’ve assembled and all-star cast to discuss the key trading perimeter, market data, consumer duty and risk surveillance issues on 22 March. Don’t miss this opportunity to dial-in to the debate. Complimentary VIP Pass Available – Apply Now! Register here for 22 March 2023


Join us to set the 2023 RegTech agenda

An all-star cast of 40+ speakers will gather virtually on 9th & 10th November 2022 to set the 2023 RegTech agenda at JWG’s 7th annual premier RegTech conference. Markets have been rocked by turbulence unseen in over a decade and the regulatory agenda has shifted quickly. JWG research has defined 10 panels and worked with the industry to


10 Sanctions RegTech priorities

The political process by which sanctions are agreed is difficult but the process for implementing them is worse. As a result, sanctions are not nearly as effective a weapon as we would like to think they could be. Ten RegTech building blocks are on the table for discussion – how do we configure a case


Digital Asset RegTech – OnDemand

This year  we will be producing 3 seminars which will facilitate regulator, firm and supplier collaboration and to develop and encourage interoperability between TradeFi and digital waves.  We are inviting Digital Asset, Crypto and TradFi market participants to join our 2022 Digital Finance Programme which will explore our global research and the role of Digital


RegTech Beacon – Guiding your way through global regulatory storms. We are delighted to publish the 28th issue of JWG’s RegTech Beacon which now serves as our yearbook that recaps 2021 accomplishments and provides an outlook of what lies ahead. Our focus this year is defining the next steps required for a truly digital financial infrastructure. 


The UK Prudential Regulation Authority (PRA) has warned firms about deficiencies in their regulatory reporting governance arrangements, systems and controls as well as the of key rules interpretations. The PRA’s ‘ Dear CEO’ letter published last week, admonished firms for their “historic lack of focus, prioritisation, and investment in this area” and called for firms


A decade ago, JWG worked with Banking Technology to produce the world’s first RegTech magazine for our sector. We are now delighted to be hosting the 6th annual RegTech / SupTech  Conference on 16 & 17 November 2021 which promises to be one of the most exciting, digital events of the season. Register Here Today Agenda


Why attend for Sponsors Why attend for Delegates Register Now   For our sixth annual RegTech conference we are bringing our global network of regulators, trade associations, academia, firms and leading technologists together to define the top challenges facing both private and public sector and debating potential strategies to overcome them. Our global regulatory debate


  By Priya Kundamal, DTCC The fragmentation of trade reporting rules and the lack of a common data set across jurisdictions hinders transparency and global risk monitoring, writes DTCC’s Priya Kundamal. Market disruptions often spur change. In response to the 2008 Global Financial Crisis, one of the G20 reforms was to mandate the reporting of


Some suggest that, had data on over-the-counter (OTC) derivatives transactions been available before the financial crisis in 2008, the build-up of risk could have been foreseen and managed very differently. This is what led to G20 demands that all derivatives products be reported to trade repositories and made available to regulators. But as early as


The number of cyber incidents at UK banks, asset managers, wholesale brokers and exchanges rose from 21 in 2019 to 55 in 2020, a 161.9% increase, according to the Financial Conduct Authority (FCA). The disclosure was made in response to a request under the Freedom of Information (FoI) Act. Asset managers, wholesale brokers, platforms and


Digital regulatory reporting – tipping point 2021

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Digital regulatory reporting – tipping point 2021 By PJ Di Giammarino, CEO JWG Group New JWG research has found supervisors to be focused on creating new standards for interpreting complex data needs in 2021 as the industry hits a tipping point for in its quest for digital standards that simplify complex regulatory reporting obligations. Global


A UK Government-led forum in its third year. A dynamic and engaging event bringing together the leading public and private sector actors from the UK, China and Southeast Asia to exchange knowledge and innovative practical techniques and solutions to tackle financial crime and related issues. A vibrant and vital interaction between policymakers, regulatory bodies, law


Collaboration to finally realize GFC reforms via digitalization The good news about compliance is that financial firms are finally getting the last generation of G20 Global Financial Crisis (GFC) regulations under control, said PJ Di Giammarino, CEO of JWG, a financial regulation think-tank based in London. The not so good news is that the industry


   Donna Bales, Co-Founder and Member of the Board of the Canadian RegTech Association and PJ Di Giammarino, Founder and CEO of JWG Group were honoured to participate in the Canadian Institute’s 26th Annual Flagship Conference on Regulatory Compliance for Financial Institutions. The trans-Atlantic debate, ‘Assessing 10 Opportunities in the RegTech, FinTech and the


Following a successful seventh reporting and reference data special interest group (RRDS 7) at the Financial Conduct Authority (FCA) on 13 February 2018, participants met for the usual post-RRDS drinks and networking session. At one point during the evening, we found ourselves mediating a friendly debate between two senior compliance officers on the post-trade reporting


Latest RegBeacon published

2017 was a year of profound upheaval for firms and regulators. As we move in 2018 we publish our latest RegBeacon, we are looking ahead and reviewing the trends shaping the global financial landscape in 2018 and beyond. Our message to the industry is that, even though we have seen off numerous deadlines and challenges


Since the financial crisis, we have been gifted over two Eiffel Towers high worth of complex and costly financial regulation, ever increasing in quantity and intricacy. Boards struggle to formulate their strategies to deal with regulatory-driven change to their operating models. There are answers, and now is the time to flush them out – before


On 21 January 2017, the European Commission (EC) published a delegated regulation and an implementing regulation in the Official Journal amending the RTS and ITS on the minimum details of the data to be reported to trade repositories under EMIR. One of the key changes made by the EC includes defining how to identify and classify


In April 2016, European Supervisory Authorities (ESA) submitted a draft Regulatory Technical Standards (RTS) for Packaged Retail and Insurance-based Investment Products (PRIIPs) Regulation, focusing on the requirements of key information documents (KID).  Despite the KID RTS being endorsed by the EU Commission, the European Parliament – in a surprising move – rejected the draft.  It


Data reporting under MiFIR

Just before the Christmas break, as part of its quick-fire release of numerous important updates, ESMA published a new Questions and Answers document that covers MiFIR data reporting.  Broken down into two separate sections, the document looks specifically at (i) LEI of the issuer and (ii) date and time of the request of admission and


RegBeacon shines light on 2017

Seismic decisions around the globe last year will make this year the most uncertain for future plans since the G20 agreed regulatory implementation priorities in 2009. Though the shifting tectonic plates of geopolitics will dominate 2017 headlines, the uncertainty doesn’t matter from an implementation perspective. There is an unprecedented level to change to get on


In our preceding article about ISINs, we explored the pursuit of a universal OTC identifier, and discussed what has occurred in Europe to fix this gap in the financial industry.  The Association of National Numbering Agencies (ANNA) created the ANNA Derivatives Service Bureau, which is based on an automated ISIN allocation engine and is scheduled


ISIN: The quest for an OTC identifier

OTC derivatives, unlike other financial instruments, have never really had a product identifier. Since as early as 2014, regulators’ high expectations for a detailed product identifier for OTC derivatives have caused consternation amongst industry experts as retooling the current infrastructure to the new specifications is an enormous task that could result in hundreds of billions


The great financial climate change

The 2016 edition of the World Economic Forum’s annual Global Risks Report lists “failure of climate-change mitigation and adaptation” as the greatest risk facing the world over the next 10 years.  That was the collective judgment of 742 surveyed experts and decision makers drawn from business, academia, civil society and the public sector. Last year’s


Dismantling data standards barriers

The push for increased transparency following the financial crisis has had a visible impact on the financial services industry.  Many regulations have created similar, but slightly different, requirements, in particular across the Atlantic.  Increased – but uncoordinated – demand on data, and proof of process in different formats and languages, without proper impact assessments conducted


The RegTech domains

In our response to the FCA’s call for input on RegTech, we recommended framing the thinking via the RegTech domains to help enable the prioritisation of new technological solutions in the context of external regulatory circumstances. As we have stressed before, RegTech is about the application of technology to solve a specific regulatory problem, not


The Fundamental Review of the Trading Book (FRTB) final text was published in January 2016 by the Basel Committee (BCBS).  The aims of the FRTB BCBS standards are to better factor market risk into trading book risk models, and to prevent banks moving instruments between the trading book and the banking book in order to


We were pleased to speak at the Asset Control User Conference on Tuesday about the challenges of using RegTech in the context of comprehensive MiFID II data requirements.  JWG’s CEO, PJ Di Giammarino, presented a helicopter view of the regulatory landscape ahead of us, an approach to getting the cost of the data under control.


JWG’s recent series on the emerging regulatory barriers and issues in FinTech, does an excellent job of setting forth the main issues for what is sure to be a busy few years of calibration for regulatory compliance and reporting. The emergence of RegTech, roughly the ways in which the adoption of new technologies can help


The new regime for transaction reporting, being introduced under MiFID II, represents a significant overhaul and expansion of what is currently required by MiFID I.  On 9 March, as part of their two-year programme on MiFID II, City & Financial Global held a highly topical event on transaction reporting under MiFID II. The last City


In the last 48 hours, significant steps have been taken towards creating a more level playing field and higher levels of transparency for those who pay tax.  This article provides you with commentary on some of the main aspects that have occurred. JWG’s Customer Data Management Group (CDMG) last year discussed the complexities that the


JWG were pleased to participate in a MiFID II webinar led by DerivSource this week. As you can see, by clicking on our presentation below, MiFID II is rekindling industry debate about the right approach to sharing billions of transaction reports across Europe. MiFID II/ MiFIR turns up the operational and technical heat, not just


Add another category to the ever expanding list of risks posed to the financial sector with the new kid on the block: Climate Change. Climate risk has now expanded beyond sheer physical damage to companies and their assets to encompass the risks posed by investments in fossil fuels and their rapidly declining value. In response


LEI: to renew or not to renew

2015 has been a year of genuine progress for the Legal Entity Identifier (LEI) project. It is fair to say that it would not have been particularly difficult this time last year to find sceptics about whether such a statement could be made at this point. ESMA have been a key driver behind this progress.


Getting your head round the main objectives of the current financial reform agenda is a task in itself, but when it comes down to the increasing data management requirements that follow hand in hand, it’s all about the nuts and bolts. Whose responsibility is it to manage this data, and keep it up to quality?


Financial regulation remains as complex as ever. Complex new niches such as shadow banking, Fintech, and Over-the-Counter Derivatives, and the increasing interconnectedness of Financial Institutions (FIs) across the world, have led to greater risks to be managed for regulators. With this in mind, how they manage to get ahead of these rapid financial evolutions and


Last week, the Regulatory Oversight Committee (ROC) published their report on the progress the Legal Entity Identifier (LEI) has made since its proposal in 2011 as a solution to transparency, organisation and risk aggregation in the financial industry. The report is split into five sections: (1) Completion of the Global Legal Entity Identifier System (GLEIS)


JWG analysis. The Regulatory Oversight Committee is branching out. On Wednesday, the ROC released a consultation paper on the possible issuance of LEIs to international branches of a head office legal entity.  The idea is that this may reduce the likelihood of the double trade and transaction reporting that foreign branches are often subject to


JWG analysis. As financial regulations keep piling up in the post-crisis world, it becomes increasingly difficult to recognise the similarities and differences between them.  The interdependencies on the Know Your Customer (KYC) front are present, but somewhat tangled.  Here we provide an overview of the current and upcoming client classification requirements under prominent regulations, and


GIIN! … LEI! … PRN?

JWG analysis. Over the course of the year, JWG’s Customer Data Management Group (CDMG) has covered in-depth customer due diligence and KYC requirements under global tax, reporting and anti-money laundering regulation, and market monitoring under MAR/MAD2.  For the ninth CDMG meeting, JWG took a different direction and covered fund management regulation and the regulatory interdependencies


JWG analysis. The minutes of the latest MiFID II implementation roundtable, on 17 July, were published in August.  At the meeting, the FCA spoke with a number of industry trade bodies, including the Association for Financial Markets in Europe (AFME), the International Swaps and Derivatives Association (ISDA) and the International Capital Markets Association (ICMA), to


Death by taxes

JWG analysis. Just as firms are getting their heads round reporting for FATCA, the OECD’s Common Reporting Standard (CRS), together with its band of early adopters, pops up.  Much has been written on comparing CRS with FATCA, highlighting that there is little to fear for there are synergies to be found.  If you are one


Yesterday, in London, an august crowd assembled to discuss the future of technology in banking.  We were privileged to participate in a session that focused on whether there is light at the end of the ‘data dilemma’ tunnel. Our conclusion: even though it’s been nearly 6 years since the G20’s plans were put in motion,


JWG analysis. We are less than 115 days from the point when the first phase of new energy trading reporting obligations kicks in across the EU.  Amidst a recent industry outcry to develop more consistent data reporting standards, the requirements introduced by the Regulation on Energy Market Integrity and Transparency (REMIT) are yet another example


JWG analysis. Eleven of the industry’s most high-profile trade associations and ISDA this week urged regulators to adopt consistent and harmonised trade reporting requirements across jurisdictions.  However, reporting rules are already on the books and the consequences are high for firms.   In part 1 of our analysis on reporting, published last week, we explored


JWG analysis. Catch phrases, like ‘caveat emptor’, have been the rallying cry of the financial industry for millennia.  In 2009, the G20 sought to change the status quo by introducing the notion of global transparency to all markets. After spending billions on the first wave of reporting, we are only now realising how difficult it


JWG analysis. European regulatory agencies were clear: firms may already be too late if they haven’t started their MiFIR implementations that need to be tested and ready in summer 2016. Speaking at a two day ‘MiFIR Reporting & Beyond’ conference attended by JWG last week, regulators, trade associations, consultants and industry practitioners we all on


JWG analysis. With 40+ regulations covering 500+ KYC data requirements due to be implemented over the next 3 years, meeting the requirements poses significant challenges to all firms in the market, not least client outreach, data management and multiple, iterative, implementation dates.  Combined with record fines for AML failures, and new personal liability for senior


By Darragh O’Grady and JWG. Regulatory requirements coming in over the next 3 years will mean firms need to know – and prove that they know – more things about their customer than ever before.  Combined with the growth of ‘digital banking’, firms are now having to innovate on the digital front, whilst ensuring compliance


On the 22nd January, over 30 stakeholders from 12 firms met Customer Data Management Group (CDMG)  meeting to discuss their 2015 priorities for regulatory KYC requirements. JWG presented a summary of 40+ new regulations that require firms to manage counterparty information over the next 3 years.  Alec then presented summaries of the 11 regulations in scope


Risk off

This article originally appeared in the autumn 2014 edition of Markit Magazine.   JWG analysis. The Basel Committee’s principles for effective risk data aggregation and risk reporting (BCBS 239) may be among the least well known components of the post-financial crisis reform package. Yet they could ultimately bring about the most significant changes to the


Trade reporting – watch out!

JWG analysis. The challenges of gaining oversight over the financial system are not going unnoticed.  We come back from the summer holidays with 5 leading indicators that suggest we are on the brink of bad news.  Bad news that is likely to spread far and wide. Firstly, in a new report, the US Government Accountability


Trade reporting fines on the horizon

By Jon Watkins, The TRADE. Regulators are set to clamp down on widespread trade reporting breaches across Europe as a six-month grace period since the rules were introduced expires, according to industry sources. Issues surrounding unique trade identifiers (UTIs), legal entity identifiers (LEIs) and the complexity of the 85 fields required by regulators have plagued


JWG analysis. The BCBS appears to be putting the screws on national regulators to expand the scope of their Risk Data Aggregation Principles to affect more banks.  Now Singapore is the first to react. June has been a busy month for all regulatory agencies, and the BCBS is no exception.  With 3 consultations, 2 sets


ESMA: “No more guidance from us”

JWG analysis. Depending on whom you listen to, Europe’s trade repositories either popped in for a chat with ESMA, or were hauled in for a stern reprimand last week.  Whichever it was, the resulting discussion was pretty explosive.  ESMA made themselves very clear; trade repositories must work harder to address low levels of inter-trade repository


In our previous article we looked at the current surveillance regime in Europe and the challenges of extending it. See here for more background on the 860 questions that need to be answered by 1 August. While not comprehensive, this will help describe three issues that should be on your checklist: context, identification and linkage.


As debate rages across the Atlantic today over controlling HFT in Chicago, we’ve been digging into ESMA’s 42 pages on transaction reporting in its MiFID II discussion paper.  See here for more background on the 860 questions that need to be answered by 1 August.  Years after Dodd-Frank upgraded the surveillance capability of the US,


JWG analysis. The continent was rocked by far more than parliamentary elections on 22 May. Early reports from major financial centres confirm the impact from the 844 pages of text released by ESMA on MiFID II / MIFID to be about a 9 on the Richter scale – so high that ESMA’s website gave up


JWG analysis. Without a consolidated viewpoint on what new risk data requirements mean, firms will be at a loss when it comes to determining best practice. We are in the middle of a massive, global industry transformation with many rulebooks. With divergent regulatory timelines, standards and existing data architectures a common and holistic ‘best practice’


JWG analysis. When MiFIR is implemented in 2016, all of the pain experienced in preparing for EMIR’s transaction reporting regime, which went live earlier this year on 12 February, is likely to be rekindled.  Thankfully, at least this time around the industry has significantly more time to get prepared. Hopefully, that means enough time to


JWG analysis. This week marked the one year anniversary of EMIR’s first implementation deadline.  And what a difference a year makes … or does it? This time last year, banks and their customers were busy determining who had passed certain thresholds (determining who would be classified as NFC or NFC+), along with implementing confirmation processes


JWG analysis. If you’re reading this post, then it’s more than likely you are in one of the many job roles that are impacted by financial regulation.  Whether you are directly involved as COO or a legal, compliance, governance or risk officer, or indirectly involved in an operational, IT or business capacity, it’s clear that


JWG analysis. “When a tree falls in the woods, does it make a noise?” While some may find the question trivial, it has provided much food for thought for philosophers since it was first raised in the early 1700s. The answer to the question relies on one’s assumptions on whether observation is a necessary condition


Transparency: the new wonder drug?

JWG analysis. MiFID II and its regulatory cousin, MiFIR, have some lofty ambitions for European securities and derivatives markets.  And one of their most clearly stated goals is to enhance market transparency by bringing about changes to market practices, and potentially even market structures. The problem is that, while transparency may be seen as a


Trade data: seeing through the smoothie

JWG analysis. When G20 leaders met in Pittsburgh back in September 2009, there was clear consensus on the direction that the financial industry needed to take in the aftermath of the global financial crisis.  Transparency was a key theme. The view was that, by mandating industry-wide reporting obligations for OTC derivatives, regulators would be armed


JWG analysis. Until the world has a definitive LEI, we are going to have to recognise that piecemeal adoption brings with it significant hidden costs in validating, enriching and mapping for regulatory purposes. LEI watchers have been encouraged to see Saudi Arabia and Italy joining the fold in the past month.  They might be just


JWG analysis. With the 12 February EMIR trade reporting deadline just around the corner, the atmosphere in the derivatives industry suggests just as much turmoil as ever. Issues surrounding LEI registration, UTI reconciliation and trade repository affiliations persist as the rush to comply with mandatory reporting rules begins.  The industry is still grappling with issues that


JWG analysis. In late October, the European Banking Authority (EBA) released a consultation on the use of the Legal Entity Identifier (LEI) for CRD IV’s risk reporting requirements.  Now that the consultation phase has been concluded, firms may only have around 60 days to register LEIs for all their entities that report under CRD IV.


JWG analysis. With 9 working days to go before compulsory reporting of derivatives trades becomes a daily reality, firms are in the final phases of implementing their individual solutions.  These differ from firm-to-firm, for example some are planning to report in real-time (as in the US), while others plan to report later within the T+1


JWG analysis. The new political drive towards tax transparency is landing in money laundering legislation, and complicating an already complex landscape. G8 Leaders, as a result of the summit held in June last year, committed to publishing ‘action plans’ setting out the concrete steps they will take to combat tax evasion. It appears that those


This time next year, the market is going to be a very different place.  No-one knows the complete, consolidated impact of regulation on the market, and many of the parts are still in motion, but the core structure is starting to take shape. In Europe, our research tells us that most institutions are opening 2014


Trade reporting for EMIR begins in February 2014 and firms are beginning to register their entities (and their clients) for LEIs in order to meet the deadline. However, registration volumes are set to increase as the EBA’s recent consultation paper indicates that the LEI will be used for CRD IV risk reporting, significantly expanding the


Counterparty classification regimes, such as CRD IV and EMIR, give banks a good reason to centralise their reference data, and the BCBS’ Risk Data Aggregation Principles provide a clear framework for doing so. From 1 January 2014, under CRD IV, firms will need to calculate CVA and hold additional capital on all derivatives contracts.  However,


Why EMIR has some banks threatening to stop trading derivatives by 15 September. Under EMIR there are three kinds of counterparties: financial (FC), non-financial (NFC), and non-financial over the clearing threshold (NFC+).  By 15 September, FCs and NFCs trading derivatives with one another must agree in writing the joint steps to be taken to mitigate


The European Banking Authority (EBA) has finally published its final draft Implementing Technical Standards (ITS) (here) on supervisory reporting for CRD IV. Long awaited, the technical standards set out the near-final reporting requirements, as part of COREP, for own funds, financial information, losses stemming from lending collateralised by immovable property, large exposures, leverage ratio and


On Thursday, consultation opened on secondary legislation from the Banking Reform Bill, which centres on implementing the Vickers recommendations to ring-fence retail banking activities. The legislation will have potentially large consequences for KYC on-boarding, risk and corporate governance. Banks are required to identify and report their ‘core’ and ‘non-core’ deposits. Core deposits must be held


FATCA delayed six months

The Internal Revenue Service (IRS) and the US Department of the Treasury has revised the timelines for implementing reporting and withholding requirements under the Foreign Account Tax Compliance Act (FATCA). These delays are very welcome to firms, particularly FFIs, still facing uncertain requirements and a short implementation timeframe. Withholding on U.S. source income, such as


Given the exponential growth of reporting requirements since the crisis, firms often ask: ‘Where does all this data go and who has the time to look through it all?’  In fact, recent statements by regulators have made this question all the more valid given that regulators’ data systems, it is increasingly apparent, often suffer from


INSEE approved as first French pre-LOU

INSEE has now gone live as the first French pre-LOU able to issue pre-LEIs. Details can be found on their website here (in French) . Translation below: The G20 has approved the unique device for intentifying market participants (global LEI system, GLEIS) agreed at the June 2012 Los Cabos Summit, which will facilitate the management


Risk regulation is a cluster bomb – multiple devices with multiple impacts – but applying uniform risk data principles can save costs in 2013-16 With six months before the 4th Capital Requirements Directive comes into force, many will be asking what technological improvements will be necessary to efficiently manage risk going forward. Before they embark


After months of being in the works, the Regulatory Oversight Committee (ROC) for the global FSB has come into being. The ROC is responsible for “upholding the governance principles of and to oversee the global LEI system … in accordance with the High Level Principles and recommendations set out in June 2012” by the FSB. In