AFB Practice Roundtable: Practical Implications of Art. 21c of CRD VI for Non-EU Headquartered Banks

AFB, in partnership with Deloitte, invites members to a practice roundtable discussion on the impact of Art. 21c of the EU Capital Requirements Directive on non-EU headquartered banks.

Why attend?

This roundtable will focus on practical and operational issues relating to compliance with Article 21c, including:

• Managing key programme challenges
  Significant obstacles (such as legal uncertainty, the alignment of global business models, or coordinating with group entities in the EU)
• Programme working assumptions
  Approaches and assumptions firms may use for areas of legal and regulatory uncertainty
• Translating legal advice into practical implementation
  How members are operationalising legal interpretations, including how decisions are documented, communicated, and embedded into business processes
• Controls, policies and business guidance
  Including pre-transaction approvals (with an emphasis on reverse solicitation); post-transaction controls and monitoring; EEA staff travel considerations; policy and procedure updates; external stakeholders; and regulator engagement strategy and reverse solicitation reporting
• Migration and client communications
• Staff awareness and training (including embedding new requirements across an organisation)

AFB will circulate an agenda and series of questions to attendees in advance to support the discussion.

The Chatham House Rule will apply to this event to encourage open dialogue and discussion.

There will be breakfast and networking from 08:15 before the roundtable discussion commences at 08:45.

Please note that there will be a limit of one representative from each AFB member to allow a wider range of firms to attend and benefit from the discussion.

Who should attend?

This session will be useful to programme leads, regulatory specialists, and senior stakeholders of Finance, Risk, Legal and Compliance teams to share insights, compare approaches, and explore emerging supervisory expectations as they progress their implementation plans.

Facilitators

Alex Szmigin – Partner

Alex is a Partner in Deloitte’s Risk Advisory Practice and is a former UK regulator with over 15 years financial services regulatory experience.  Alex co-leads Deloitte’s CRD VI offering and has supported several banks in developing their approach to achieving compliance. Alex supported a number of banks with Brexit planning and post-Brexit solutions.

Clare Jenkinson – Partner

Clare is a Partner in Deloitte’s Legal practice, with extensive experience of large, multi-business, multi-jurisdictional regulatory change projects. In conjunction with Alex Szmigin, Clare co-leads Deloitte’s CRD VI offering, and is advising several firms on CRD VI.

Fauzi Waraich – Partner

Fauzi has over 19 years of Professional Services experience with a specialism in Capital Markets. He is one of the Risk and Regulation leads within Deloitte’s Technology & Transformation business, leading the Operating Model Transformation team. He has worked across front-to-back change programmes on the regulatory agenda, legal entity restructuring, operating model, cost reduction and operational efficiency topics.

James Henson – Director

James is a Director in Deloitte’s Legal practice, specialising in wholesale banking and capital markets regulation. James supports many aspects of Deloitte CRD VI’s offering, including Article 21c rules and the requirements for third-country branches.

Richard Tosh – Assistant Director

Richard is an Assistant Director within Deloitte’s Risk Advisory Practice and supports clients in delivering complex change programmes, regulatory engagement and approvals. Richard is a core part of Deloitte’s CRD VI team. He has deep-level expertise on regulator engagement across major change programmes.

Logistics 

Fee:            Included in AFB membership  
Format:      In-person at Deloitte, 2 New Street Square, EC4A 3BZ 

                   (nearest stations: Farringdon or Chancery Lane)
Date:          Thursday 11 June 2026
Time:          08:45-10:15 (Arrivals and breakfast from 08:15)

If you would like to submit a question before or have any specific areas that you would like the session to address, please send them to the AFB at secretariat@foreignbanks.org.uk You will receive details on how to join the session one week before the event.