Benchmark Administrator
Elucidate GmbH is a registered Benchmark Administrator under Article 34 of the EU Benchmark Regulation (BMR), listed on the ESMA register and supervised by the Federal Financial Supervisory Authority (BaFin) in Germany.
The regulation
The Benchmark Regulation (BMR) — Regulation (EU) 2016/1011 — governs indices used as benchmarks in financial instruments and financial contracts, and indices that measure the performance of investment funds.
Its objective is to reduce the risk of benchmark manipulation by addressing conflicts of interest, governance controls and the use of discretion in the benchmark-setting process. Administrators are supervised by their national competent authority and listed on a public register maintained by ESMA, the European Securities and Markets Authority.
The BMR is equivalent to comparable standards in other markets, including Singapore and Australia, and is widely recognised as the reference standard for the regulation of benchmarks and indices.
The benchmark
The Elucidate FinCrime Index (EFI) is a financial crime risk benchmark administered under the BMR — the first in its field to come under this oversight, in August 2020. It defines a standard for measuring financial crime risk, so that financial institutions can score and price the risks of money laundering, corruption, tax evasion, trafficking and terrorist financing on a common, defensible basis.
Elucidate was also the first financial crime RegTech to bring the provision of its software under regulatory supervision. Every EFI result is produced under the governance, methodology and input-data controls the BMR requires, so the outputs are:
Produced under a documented methodology and governance framework that can be examined by a supervisor.
Input data is controlled and the calculation is repeatable, so the same inputs give the same score.
Conflicts of interest are identified and managed; the benchmark is not set by the institutions it measures.
The benchmark statement, compliance statement and procedures below are published for anyone to read.
Documents
As a Benchmark Administrator, Elucidate GmbH publishes the following disclosures associated with the provision of the Elucidate FinCrime Index.
What the Elucidate FinCrime Index measures, the input data and methodology it uses, and the circumstances in which it may not be reliable.
The compliance statement required of administrators of non-significant benchmarks, setting out which BMR provisions Elucidate applies.
How to raise a complaint about the benchmark or its administration, and how Elucidate investigates and responds.
The protocols governing the input data contributed to the Elucidate FinCrime Index, published on the Elucidate documentation site.
The procedure Elucidate follows if it changes the methodology of, or ceases to provide, the Elucidate FinCrime Index.
Questions
For questions about the Elucidate FinCrime Index, its methodology, or any of the disclosures above, get in touch with our team.
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