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ARTICLE · 31 DECEMBER 2024

Are products traded with a Systematic Internaliser considered OTC?

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The EMIR Refit Validation Rules apply in the EU from 29 April 2024 and in the UK from 30 September 2024.

United KingdomFinance and Banking
Quinn Perrott
Quinn Perrott
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A Systematic Internaliser (SI) is an investment firm that, when executing client orders over-the-counter (OTC), multilateral trading facility (MTF), or organised trading facility (OTF), deals on its own account in an organised, frequent, systematic and substantial manner without operating a multilateral system (see Article 4(1)(20) of MiFID II).

Summary

  1. The question of whether an International Securities Identification Number (ISIN) is required to be used or not depends on the product traded, not the SI.
  2. An ISIN must be populated when the 'Venue of Execution' field contains a market identifier code (MIC) of a trading venue within the EU.
  3. An ISIN is optional when the 'Venue of Execution' field contains a MIC of a SI.

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