For those readers who might have missed this, please note that ESMA has set up monthly meetings of EU National Crime Agencies in order to review the substance requirements of "Brexit/EU Hub" applications sponsored by UK firms. So far there have been four monthly meetings.
Based on recent discussions with national regulators, we understand that the Irish CBI has not submitted any applications to this committee. As a result, UK clients hoping to set up an EU Hub in Ireland without employing staff in Ireland should be aware that this approach has not been reviewed (or approved) by ESMA; and it is very likely that such arrangements will not meet the ESMA "substance" requirements.
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