Written on: 16 June 2025
FMSB Senior Technical Specialist Mimi Yan leads the activities of FMSB’s Post-Trade Committee which aims to find practical, industry-wide solutions to post-trade and other operational issues in wholesale markets.  Here she shares more about the Committee’s work and her role in a Q&A.

1. You’ve been helping to support the work of FMSB’s Post-Trade Committee since it was established in 2022. Can you tell us more about how and why the Committee came into being?

Senior Technical Specialist and Post-Trade Lead, FMSB
April 2022 marked the publication of the Post-Trade Task Force’s final report. This was a cross-market group of operations experts, convened by the Bank of England and Financial Conduct Authority, and chaired by David Hudson, who still leads FMSB’s Post-Trade Committee. The report contained recommendations across three areas: Non-Economic Trade Data, Client Onboarding, and Uncleared Margin. However, to achieve the critical level of adoption required for these recommendations to be successful, would require consensus across the markets on the details of their implementation. Being a cross-market and consensus-led organisation, the then Executive Director for Markets of the Bank and Director for Markets at the FCA, approached FMSB and its Members to take forward this work and we have now delivered a publication on each of the three topics: two Standards on Standard Settlement Instructions and Client Onboarding, and one Spotlight Review on Uncleared Margin (in May 2025). We are now looking to new areas where standardisation could benefit the market, with Digital ID being the first new workstream.

2. Client Onboarding: Documentation and Processes was the Committee’s first Standard, issued in final form in December 2024. What is this Standard intended to help firms with?

To take a step back, the purpose of client onboarding is to get to know a new client, or refresh a relationship with an existing client, sufficiently well that future business can be conducted efficiently, and in the knowledge that such business is for legitimate purposes. These are very worthy goals. However, there has been growing consensus that the divergent approaches taken by firms (which under many jurisdictions’ Anti Money Laundering regulations is principles-based) have led to unnecessary inefficiencies. This not only costs the onboarding firms but the clients too, in the form of both costs, and lost opportunities to conduct business.

This Standard is intended to harmonise the baseline data point and documentary requirements for onboarding a client, while recognising that KYC is still a risk-based exercise. The implication for clients is that they now have a common core set of documents that can be presented to any institution which subscribes to the Standard, and onboarding firms can reallocate resources to other strategies to combat financial crime – such as transaction monitoring. It is a huge topic, so the first edition of the Standard focuses on the UK’s regulatory requirements, but we hope to see positive results following its adoption, in which case, the Working Group is enthusiastic about expanding to other jurisdictions as well. 

3. The Committee issued a second Standard for Sharing of Settlement Instructions (SSIs) in final form in January 2025. Can you tell us more about why it’s important to try and make the sharing of SSIs more efficient and how this Standard can help?

SSI-related issues are one of the largest causes of settlement fails, and yet automated solutions, which both significantly cut down on the risk of errors, and reduce the operational inefficiencies of manually-sent SSIs, are not fully adopted by the market. With T+1 settlement already in place, or being implemented, in more and more markets, everyone will have significantly less time to correct any errors, and run the real risk of a failed settlement.

The Working Group quickly identified a gap in previous efforts to increase automation – they were targeted at the clients, when many clients in fact use custodians to manage their SSIs on their behalf. These custodians have the infrastructure to be able to automate their clients’ SSIs, but the conversations were rarely being had. That’s why the scope covers not just Members’ own SSIs, but those of their clients where that agent relationship exists.

There was also recognition, however, that there may remain a segment of the market where automation isn’t operationally or legally feasible. How that works today is that SSIs are communicated in different formats, using slightly different taxonomy. The Working Group therefore also took the opportunity to review market standards for taxonomy, and combined this with new templates which can be used for the residual, manual portion of the market. This ensures that market participants are talking a common language – and facilitates SSI receivers, who may wish to automate the ingestion of such SSIs on their own end.

4. You also wear a different, voluntary hat, as Co-Lead of the Operational Issues Working Group for the UK Accelerated Settlement Task Force Technical Group (TGT+1). Can you tell us a bit about that role and how it complements your work with the Post- Trade Committee?

The Operational Issues Working Group covers four distinct segments: static data, settlement, Financial Market Infrastructure resilience, and corporate actions. For each, the question at hand has been – what needs to be done ahead of the UK move to T+1, and how can this be achieved? We’ve had the fortune of excellent sub-stream leads, and a large number of Subject Matter Experts who have volunteered, and continue to volunteer, their time – as well as strong support from all the UK authorities. Although distinct from the Post-Trade Committee work, there are definite synergies. For example, had it not been for the Post Trade Task Force front-running the efforts to create SSI standards, it would have been challenging for the market to have compiled the Core Principles and Templates to the level of detail required, and in the time required for the market to adopt. And the benefit of large market changes such as this one means that a spotlight is shone on operational issues – creating a focus on implementation.

5. You attended the global financial conference Sibos in Beijing in 2024. Can you tell us a bit about what you spoke about and learnt from the experience?

Our panel was about accelerated settlement, with speakers from around the world and representing all segments of the market – investors, to custodians, regulators, and market-led initiatives such as the UK Accelerated Settlement Taskforce (and of course FMSB). It was great to hear both from the other speakers, and audience polls, as to the support that accelerated settlement has across the market – but cautious support, as in today’s globalised markets, cross-border considerations and allowances for time zones need to be clearly thought out. There were some excellent other sessions too, and a general thematic: we all know that better data is important for operations – but to see the extent of support for greater standardisation, and the potentially transformative applications of new technologies, was eye-opening.

6. What next for the Post-Trade Committee in terms of its workplan?

We’re focused on Digital ID (for non-natural persons) at the moment. It’s a natural extension of the Client Onboarding work – going from disparate ways of proving a corporate’s existence and key data about it prior to the Client Onboarding Standard, to a more harmonised framework after, and now hopefully the ability for a corporate to be “one and done” – at least with respect to core data.

Senior Technical Specialist and Post-Trade Lead, FMSB
Mimi at Sibos in Beijing
As a human person, it’s amazing to think about the ease at which we can cross borders today, and much of that has been the incredibly detailed international work done around standardising the form, contents, even the specifications around printing. With the relatively recent addition of the biometric chip, newer passports are securer than before. It doesn’t mean that visas aren’t required for specific kinds of visits, or to certain countries. It doesn’t guarantee entry. And it doesn’t mean that there is never fraud. But with one single pocket-sized booklet, we can prove who we are to the satisfaction of border agents around the world that we are who we say we are. We can, and should, be doing the same for corporates.

7. Before working for FMSB, you spent a decade working in Capital Markets structuring, Risk, and Treasury functions, including stints at Bank of America Merrill Lynch and Credit Suisse. What drew you to FMSB?

It certainly seems like an odd portfolio of jobs on the surface! But what links them all is, at the time I held those roles, they were all areas undergoing significant regulatory change. My job always touched on either, or both, of what that change should be at a policy level, or how best to implement in a balanced, rational manner. I enjoy working through change; it gives us a space to step back and think about how we want the world around us to look like, and the intellectual challenge of identifying all the stakeholders and tangential problems to consider. Nothing feels more satisfying than successfully negotiating the package and bringing that all together, and being on the Secretariat for FMSB delivers this every day. As a teenager, I used to want to be a diplomat for the United Nations; quite often it feels like I’m doing just that now, but for financial market participants, rather than countries! 

8. When you are not working hard helping support FMSB Members to make post-trade processes more efficient what do you enjoy doing in your spare time?

The more unusual hobby first – I am one of very few people worldwide today who creates Shetland lace.This is an ancient technique which combines wool almost as thin as a human hair with delicate geometric patterns, and knits them into huge shawls, yet which should ideally fit through a wedding ring. We often think about “crafts” as less worthy than “arts”, but some of these heritage designs combine engineering with maths and aesthetics, and are beautiful.I also returned to ballet a few years ago. What is wonderful about ballet is that it requires complete concentration in the moment, and being on your toes, inhibiting the music, takes you to a different world. It is also a very humbling activity – so much can go wrong, and everything can always be better. Thinking about it, what unites them is their precision and strive towards perfection. Perhaps there is a tenuous link to standardisation and operational efficiency!

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