AFME confirms MiFID 2 share trading obligation views

AFME has published a note setting out its views as to why the share trading obligation under MiFID 2 applies to a MiFID investment firm only when it is the final entity in the chain of execution. It says a firm that places or transmits an order to another firm, regardless of whether that other firm is an EU firm or not, the original firm does not “undertake” the trade and as a result the share trading obligation does not apply.

AFME felt it needed to make this clarification as MiFID 2 does not define “undertake” in this context.