FIA has created a brief to help members understand how the Markets in Financial Instruments Directive II and the associated Markets in Financial Instruments Regulation may impact U.S. futures commission merchants. The brief, which was developed with the law firm Katten Muchin Rosenman UK, focuses on compliance obligations for U.S. FCMs and their non-EU clients when MiFID II and MiFIR take effect on Jan. 3, 2018. The brief may also be instructive for other third-country firms, including principal trading firms and market participants in Asia-Pacific. The brief addresses three separate compliance concerns: direct impacts from authorization requirements, direct impacts from ongoing compliance obligations, and indirect impacts where firms may be affected by the application of new obligations on the European market participants with which they do business.
