How healthy is your MiFID II programme?

24 April 2017

By Nassim Daneshzadeh and Alastair Findlay

The days are lengthening, spring is in the air and it’s time to shake off the winter colds. However, for some of us the dog days of winter and the huge task of MiFID II implementation cannot so easily be shaken. What seemed a long way off has suddenly become very real and very close. But how healthy is your MiFID II programme?

This is becoming an increasingly frequent question. We hear lots of stories of lack of resource, particularly in the technology space, lack of budget, lack of technical clarity from the regulator and lack of business engagement. RAGs are rouging but there remains a sense of opacity around the true state of what is the largest regulatory change in a decade.

Whether it’s asking for more budget and resource or knowing which work streams need further attention, executive management, senior managers, project sponsors, compliance and internal audit are all trying to understand the state of play and how to better steer the ship to compliance on 3 January 2018.

A health check of your MiFID II programme needs to be detailed enough to diagnose the problems but not so invasive as to stall critical implementation efforts. It needs to come at the right time when there is enough of the implementation to review whilst leaving enough time for key gaps to be remediated before senior managers find themselves on the hook from early next year. 

We believe this health check should focus both on the programme governance and management as a whole as well as the individual work streams/content areas and should examine the following factors:

  • Governance (including governance and policies and procedures)
  • Target Operating Model and Front to Back Responsibilities post MiFID II
  • Critical processes specific to the topic area
  • Operational risk/controls to deliver sustainable compliance
  • Training
  • Compliance oversight and monitoring

It’s time to take your MiFID II programme’s temperature before it’s too late.

If you are interested in a discussion around the topics raised in this piece please contact us at and

Nassim Daneshzadeh: View Nassim Daneshzadeh'sprofile on LinkedIn   

Alastair Findlay: View Alastair Findlay profile on LinkedIn   



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