What consequences does Brexit have for investment firms or managers of collective investment schemes that work with investment firms in the UK?
An investment firm you work with in the UK will no longer be able to continue providing its services. The investment firm will need a licence in an EU Member State to be allowed to continue providing investment services in the Netherlands.
Reverse solicitation, i.e. the offering of services exclusively at the client's own volition and without inducement, will not enable it to continue to provide its investment services. Only in very exceptional circumstances will reverse solicitation offer clients an opportunity to enter orders with a company established in the UK. This will need to be assessed on an order-by-order basis and must meet a set of strict conditions. You should also refer to the Q&As published by the ESMA on this matter (Chapter 13).
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