Clifford Chance
The regime for third country Firms under MiFID II / MiFIR - The outlook from Spain
16 February 2017
Key issues
- MiFIDII/MiFIR introduces changes to the Third Country Regime
- There will be different options, depending on the type of client
- Member states will have discretion to decide if local branches are required in some circumstances.
- The Spanish regulator has not yet stated its position on this issue
- Current business models might be affected post Brexit
- Firms operating under the Third Country Regime should consider the issues well in advance of the 1 January 2018 MiFIDII/MiFIR implementation date
