The Cross-Border Licensing Regime Enters into Force on 20 March 2019

Authors: Sanna Boow, Senni Mäki-Hallila and Jari Tukiainen

The new Finnish cross-border licensing regime enters into force on Wednesday 20 March 2019. As mentioned in our previous blog, the new legislation permits third-country firms, including UK firms after Brexit, to apply for a permission to provide investment services on a cross-border basis to per se professional clients and eligible counterparties in Finland under a new type of a licence.

Brexit: Finnish Temporary Permission Regime

The Finnish Financial Supervisory Authority (the “FIN-FSA”) has already been accepting licence applications from UK firms in advance of the law amendments entering into force.

By submitting a licence application before Brexit (currently, by 29 March 2019), a UK firm can benefit from the Finnish temporary permission regime. This means that such a UK firm may continue to provide investment services to per se professional clients and eligible counterparties in Finland after Brexit in accordance with, and to the extent covered by, its MiFID passport in Finland until the FIN-FSA has processed the application. The FIN-FSA has to process the application within six months of receiving the complete application.

Hannes Snellman Assists with Cross-Border Licence Applications

Hannes Snellman is assisting a large number of UK investment firms and credit institutions in applying for the cross-border licence from the FIN-FSA.

Our financial services regulation team is available to discuss any questions on the licence, and we are happy to assist you in applying for the licence before Brexit.