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FCA wants to highlight that some proprietary traders who are not authorised may need to be authorised under MiFID II.
For example, if you are an unregulated proprietary trader who uses a form of direct electronic access provided by a regulated firm to access trading venues (a ‘DEA client’), you may need authorisation from 3 January 2018. You need to confirm urgently whether you will need authorisation and, if so, make an application.
If you are a firm or venue providing your clients with direct electronic access to trading venues (a ‘DEA provider’) you will have a duty under MiFID II to carry out due diligence on your prospective DEA clients. You should therefore work closely with your clients to ensure they are aware of the potential need to be authorised and be authorised on time.