On January 21, the UK Financial Services Authority (FSA) published the results of its thematic review of the implementation of a number of key “wholesale” requirements of the EU Markets in Financial Instruments Directive (MiFID). MiFID introduced certain new, more extensive requirements for FSA authorized firms, including new conduct of business and organizational requirements.

In September 2007, the FSA identified wholesale and retail business areas of MiFID that were a priority for its review. The wholesale priorities included: (i) best execution; (ii) inducements; (iii) investment research; (iv) client classification; (v) conflicts of interest; and (vi) senior management systems and controls. The thematic review was undertaken between June and November 2008 and included 43 wholesale firms.