Although Article 50 has only recently been triggered, we in the UK are still bound by EU regulation and in particular the Markets in Financial Instruments Directive (MiFID II) and Regulation (MiFIR) which come into force on 3 January 2018.
These require that all entities, including charities, which hold, or trade in, ‘reportable investments’ (i.e. listed investments) must obtain a Legal Entity Identifier (LEI) — a unique 20 digit number which is used to report transactions to the Financial Conduct Authority. This information is used to facilitate the monitoring of financial crime, including insider dealing.
Charities needing an LEI must apply to a body which is authorised to issue them and must have these renewed annually. The LEI must be in place prior to 3 January 2018; failure to obtain an LEI will mean that investments cannot be traded.
We will be helping our (investment) clients obtain LEIs by collating the required information and submitting it to the relevant body and will be writing to affected clients in due course.
By necessity, this briefing can only provide a short overview and it is essential to seek professional advice before applying the contents of this article. This briefing does not constitute advice nor a recommendation relating to the acquisition or disposal of investments. No responsibility can be taken for any loss arising from action taken or refrained from on the basis of this publication. Details correct at time of writing.