One of the largest ever set of reforms to the European financial sector, MiFIR and MiFID II, comes into force today, Wednesday, 3 January 2018. Firms have been undertaking vast amounts of preparation to ensure compliance with minimal disruption to business.
Amongst the many obligations for investment firms contained within MiFIR and MiFID II is an enhanced and expanded transaction reporting requirement. We covered preparations for this requirement last month in our article “One month until MiFID II go-live”.
Since then, ESMA has announced a six month grace period for the requirement to report counterparty LEIs where one is not available. The relief applies in circumstances where the counterparty has not been issued with an LEI and where you have obtained all necessary information to obtain an LEI on their behalf.
In September 2017, we heard from the FCA on their approach to enforcement, where the sentiment was one of balancing the scale and difficulty of the reforms with a need to take “sufficient steps” to meet the new obligations.
The process of financial sector reform through MiFID and MiFIR is likely to be an ongoing process, so you should aim to even after today’s implementation date.
In light of this, feel free to contact us any time if you would like to discuss your regulatory obligations on +44 20 8050 1317.