MFID II

A legal entity identifier (LEI) is a unique, alpha-numeric code of 20 characters which identifies legal entities that engage in financial transactions with investment firms in the EEA. When an LEI code is allocated, it is included in the Global LEI Foundation database. This enables every legal entity or structure that is party to a relevant financial transaction to be identified in any jurisdiction. 

You will need to have an LEI to trade with SMBC Group for in-scope MiFID II transactions within the EEA, irrespective of where you are located. You must register with an authorised local operating unit (LOU) which issues LEIs. A list of all authorised LOUs can be found on the Global LEI Foundation website. LEIs must be renewed annually. To do this you must provide the LOU with updated information so that they can verify the data held on the LEI. 

A systematic Internaliser (SI) is an investment firm which, on an organised, frequent, systematic and substantial basis deals on own account by executing client orders outside a regulated market, a multilateral trading facility or an organised trading facility without operating a multilateral system. 

From 24 October 2018, the following entities are SIs for foreign exchange (FX) derivatives that are traded on a trading venue with the corresponding SI market identifier codes (MICs): 

Please note, the European Securities & Markets Authority (ESMA) has deemed the entire FX derivatives asset class as an illiquid market. 

The SI commercial policy applies to business conducted on FX derivatives markets where SMBC Group has authorisation to carry out regulated activity in financial instruments as defined in MiFID II in the EEA. 

PDF Systematic internaliser commercial policy (SMBC and SMBC BI) 

PDF Systematic internaliser commercial policy (SMBC Nikko) 

Client letters 

PDF Systematic internaliser client letter (SMBC Nikko – 1 May 2019) 

PDF Systematic internaliser client letter (SMBC Nikko – 1 September 2018) 

Investment business information packs 

The information packs consolidate certain requirements such as order execution, risk disclosure, conflicts of interest and other necessary information into a single document for clients of SMBC EU. 

PDF Capital Markets Investment Business Information Pack (SMBC EU - 1 August 2024) 

PDF Global Markets Investment Business Information Pack (SMBC EU - 14 August 2025) 

Order execution 

The order execution policy applies to business conducted with professional and retail clients of SMBC Group in the EEA. It is designed to inform SMBC Group's clients on how transactions are executed to provide a general understanding of SMBC Group’s dealing arrangements by product type in line with the best execution requirements as defined in MiFID II. SMBC Group will need to obtain your prior consent to the policy and your express consent to executing any orders outside of a trading venue. The policy is reviewed on an annual basis or where there is a material change that affects our ability to obtain best execution. Please note that this policy does not apply to eligible counterparties unless agreed otherwise. 

PDF Order execution policy 

En français (in French) 

PDF Politique d’exécution des ordres 

PDF Formulaire de notification de consentement 

Risk disclosure 

The risk disclosure notice contains a general description of the principal risks arising from financial instruments which are generally offered to clients. 

PDF General description of the nature and risks of financial instruments 

Conflicts of interest 

Under MiFID II, SMBC Group is required to maintain and operate effective organisational and administrative arrangements with a view to taking all reasonable steps to identify, monitor and manage conflicts of interest. 

PDF Summary of conflicts of interest policy 

En français (in French) 

PDF Résumé de la politique de gestion des conflits d’intérêts 

SMBC Group is required to inform clients of the costs and charges for services offered and products traded on an ex-ante (pre-trade) basis in accordance with MiFID Article 24 of Directive 2014/65/EU and Article 50 of MiFID II Delegated Regulation. This is an estimation of costs that will incur prior to providing investment services and activities or ancillary services as defined under MiFID II. 

PDF Ex-ante costs and charges (SMBC and SMBC BI) 

The allocation policy is expected to apply in respect to the process of underwriting and placing of securities offerings. It is designed to ensure that the allocation process is conducted in a fair and transparent manner and in accordance with appropriate standards of market conduct, the issuer and investor clients are treated fairly, conflicts of interest are appropriately managed through effective organisational and administrative arrangements, and an orderly market is maintained.  

PDF Summary of allocations policy 

Under MiFID II, SMBC Group is required to take all sufficient steps to obtain the best possible result for clients when executing their orders. Moreover, as a liquidity provider, SMBC Group is under an obligation to publish quarterly reports on the quality of execution of transactions, known as the RTS 27 report. It includes details about the price, costs, speed, and likelihood of execution for each type of financial instrument in respect of which we act as a liquidity provider. 

RTS 27 reports are available on our Notices & Reporting page and have been prepared on best efforts basis. SMBC Group reserves the right to amend the reports if deemed necessary. 

Top five execution venues in terms of trading volumes for all executed client orders per class of financial instruments and a summary of the analysis and conclusions drawn from detailed monitoring. View RTS 28 related documents on our Notices & Reporting page.