MiFID II went live on 3 January 2018. In scope, firms will have considered the impact of the regulatory changes being introduced, but may not be aware of the VAT implications of MiFID II in respect of the provision of research.

With just 36 working days remaining of 2017 and until the implementation of MiFID II, we are seeing mixed progress towards compliance, with some firms just completing the first hurdle as they progress through the gap analysis stage. While others have demonstrated strong progress towards implementing solutions and now have the finish line in sight, as we enter the final furlong.

With just 3 months left to achieve compliance with MiFID II implementation due on 3 January 2018, we've highlighted below 7 key areas that are pertinent to most firms across financial services.  

With the Prime Minister Theresa May indicating that there is insufficient time to replace European bodies with a new British regulatory regime, the implications of Brexit look to have limited short term impact on Financial Services regulation. However, beyond March 2019, what would a hard or soft Brexit look like in terms of future regulation?

With only seven months to go until its implementation date, MiFID II is one of the most talked-about topics in the financial industry. However, we are still finding that a number of firms fall victim to some misinterpretations and common misconceptions about the changes brought about by MiFID II.

By 26 June 2017, all European Union member states are required to have enacted the Fourth Money Laundering Directive (4MLD) into national law. 4MLD aims to give effect to the updated Financial Action Task Force (“FATF”) standards. With this in mind Firms need to make sure their policies, procedures, systems and controls are up to scratch.

With an implementation date of 3 January 2018, the deadline for readying your firm for the required changes is rapidly approaching. However, in a recent Moore survey, it was found that only 7% of firms had started their implementation plans and more than half did not even have a plan in place yet to achieve timely compliance.
 
To aid firms in scope of MiFID II, this article highlights the key milestones you need to work towards over the coming nine months.

The FCA announced the opening of the MIFID II authorisations gateway on 30 January. It is thought that around 600 applications will be submitted over the coming months including new applications for authorisation of organised trading facilities, commodities dealers and data reporting service providers. Similarly, variations of permissions and notifications from existing firms that require a change of permission or passporting rights are expected.