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AFB Practice Roundtable: The New Prudential, Regulatory and Supervisory Requirements for Third Country Branches Under CRD VI

AFB is partnering with A&O Shearman for a second in-person roundtable discussion on the EU Capital Requirements Directive VI (CRD VI).

The first roundtable was held on 18 April 2024 at Allen & Overy; attendees discussed the prohibition of cross-border business into the EU enacted by CRD VI and the impact this would have on their banks.

This second roundtable will provide the opportunity to discuss further aspects of the Directive. In particular, the new prudential, regulatory and supervisory rules for existing third country branches operating in the EU. For example:

  • the requirement to autonomously manage the assets and liabilities booked or originated by the third country branch
  • the minimum capital endowment and liquidity requirements
  • the rules requiring the implementation of reporting lines to Head Office
  • the (re-)authorisation requirement and the subsidiarisation mechanism.

You are welcome to attend this event whether or not you attended the first roundtable. Please note the roundtable is aimed at AFB members representing non-EU banks that currently have / are planning to open a third country branch in the EU.

Kirsty Taylor (Knowledge Counsel) and Bob Penn (Partner), from A&O Shearman, will provide a short overview of the EU’s new requirements. AFB members will then have the opportunity to discuss and share their understanding of the rules, how they will be affected and the challenges they are facing.

AFB will circulate an agenda and a series of questions to those registered to attend in advance which will be used to aid the discussion. The Chatham House Rule will apply to this event to encourage open dialogue and discussion.

There will be refreshments and networking from 15:30, before the discussion starts at 16:00.

Note that capacity for the roundtable will be limited to 25 members, one person per member bank. We recommend booking early to secure your place.

Who should attend?

This session is primarily aimed at AFB members representing non-EU banks that currently have / are planning to open a third country branch in the EU.

We recommend attendees from the following business areas join the session:

  • Legal
  • Regulatory change
  • Compliance

What will members gain for use?

  • A general understanding of the final CRD VI rules for third country branches
  • The opportunity to discuss how non-EU banks will be affected by the new rules
  • An understanding of how non-EU banks can begin to prepare for implementation
  • An opportunity to discuss the challenges faced when adapting businesses to meet the CRD VI requirements


Bob Penn – Partner – A&O Shearman

Bob advises banks, asset managers, market infrastructure providers and other financial institutions on a wide range of national and international regulations. He has led A&O Shearman’s substantial work on the European financial services reform agenda, including advising on revisions to capital requirements, the introduction of recovery and resolution plans and retail ring-fencing for banks and on changes to derivatives markets.

Bob is the author of two chapters in the Oxford University Press publication on Financial Markets and Exchanges Law, covering UK recognised investment exchanges and clearing houses and alternative trading systems respectively. Bob gave evidence to the UK Parliamentary Commission on Banking Standards in relation to proposals for the ring-fencing of retail banking activities in the UK. He sits on the IIF Special Committee on Effective Regulation.

Bob is recognised as a leading individual for regulatory advice by Legal 500, Chambers & Partners and IFLR 1000 and is regularly quoted in the press on regulatory matters.

Kirsty Taylor – Knowledge Counsel – A&O Shearman

Kirsty maintains a wide-ranging practice of core regulatory advice across banking and investment bank businesses.

She has particular experience of advising on and managing significant regulatory change initiatives and frequently works with industry bodies and trade associations to help respond to regulatory and legislative proposals.


The easiest way to book your place is through the AFB’s automated events booking system on the website.  Please note your username is your bank e-mail address and if you cannot recall your password, or have not yet set one up, you can click the ‘Recover your login details’ option on the login page and follow the instructions.

Cost:        Included in AFB membership (no fee)

Location:  A&O Shearman, One Bishops Square, London, E1 6AD

Date:        Tuesday 11 June 2024

Time:        16:00 – 17:30 (arrivals and networking from 15:30)

There will be ample opportunity for questions throughout the session, however, if you would like to submit a question before or have any specific questions or areas that you would like the session to address, please send them to the AFB at as soon as practicable. You will receive details on how to join the session one week before the event.