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Germany: Germany’s CRD6 Draft Implementation – 7 Key Takeaways for non-EEA firms (TCB)

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In brief

This marks an important, substantial step towards a new harmonized and more restrictive regime for branches of non-EU/EEA firms, e.g., from the US, UK and Asia, which provide “core banking services” of deposit-taking, lending, and providing guarantees and commitments to German clients, so-called third-country branches (“TCB“) under Art. 21c CRD6. The new regime will have a significant impact on business models, including new requirements on governance, booking, risk management and reporting.

This briefing summarizes the key provisions of the German Draft Implementation Act and their implications for non-EU/EEA firms. For a general overview of the TCB regime, see our Client Briefing The New EU Third Country Branch Framework: What Firms Need to Know published in November 2024.

Click here to read the full alert.

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Dr. Conrad Ruppel is a financial regulatory partner in Baker McKenzie's Banking & Finance Practice Group in Germany, Frankfurt. Conrad advises financial services clients, investment banks, fund managers and institutional investors on a wide range of financial regulatory issues throughout the business lifecycle. A particular focus of his work is on FinTech and digital assets projects. Prior to joining Baker McKenzie in 2024, Conrad worked for leading German and international law firms. He has gained work experience at Goldman Sachs and Morgan Stanley in Frankfurt and London during his client secondments. Conrad was admitted to the German bar in 2014. Conrad is a university lecturer at the ILF (Institute for Law and Finance) at the Goethe University Frankfurt and at the Fulda University of Applied Sciences. He has authored a number of articles and contributions for leading journals and other publications.

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Manuel Metzner is a counsel in Baker McKenzie’s Frankfurt office. Prior to joining the Firm, Manuel was counsel at a renowned international law firm, where he practiced in the areas of corporate, M&A, capital markets, financing and financial regulatory for almost 20 years.

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Katharina Wollmert is an associate in the Banking & Finance Practice Group/Financial Services Regulation of Baker McKenzie in Frankfurt since October 2024. Prior to joining Baker McKenzie as an associate, Katharina worked for another international law firm as an associate and advised a diverse range of international clients on regulatory matters.

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