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Set forth below is the joint view of the undersigned law firms on the German regulatory position for UK broker-dealers who continue to deal in financial instruments with broker-dealer counterparties based in Germany following a hard Brexit (i.e. no transition period, no equivalence decision for UK investment firms pursuant to Article 47 of Regulation (EU) No 600/2014 (MiFIR)). In this paper, references to German broker-dealers mean any bank or broker-dealer (including German branches of foreign firms) based in and operating from Germany and undertaking the regulated investment ser-vice or activity of dealing on own account (Eigenhandel and Eigengeschäft). References to UK bro-ker-dealers similarly mean any bank or broker-dealer (including UK branches of non-UK firms) based in and operating from the UK and undertaking the regulated investment service or activity of dealing on own account with a German broker-dealer.
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