Intesa Sanpaolo Systematic Internaliser - IMMH and Designated Publishing Entity - DPE

Pursuant to Article 4(1)(20) of Directive 2014/65/EU (MiFID), a Systematic Internaliser is defined as an investment firm which, on an organised, frequent, systematic and substantial basis, executes clients orders on its own behalf outside a Regulated Market (RM), Multilateral Trading Facility (MTF) or Organised Trading Facilities (OTF)¹.

The Intesa Sanpaolo IMI Corporate & Investment Banking Division voluntarily chose to become a Systematic Internaliser on all bond financial instruments (excluding ETCs and ETNs) as from 3 September 2018.

The MIC (Market Identifier Code) through which the activity carried out as Systematic Internaliser is identified is IMMH.

The LEI (Legal Entity Identifier) code of Intesa Sanpaolo is 2W8N8UU78PMDQKZENC08.
As a Systematic Internaliser, Intesa Sanpaolo executes OTC client orders and provides quotes through its designated commercial channels whenever it accepts OTC Request for Quotes (RFQs) received in electronic format or via voice/chat.

However, following the entry into force of Regulation (EU) 2024/791 on March 28, 2024, which repealed, inter alia, Article 18 of Regulation (EU) 600/2014 (MiFIR) concerning pre-trade transparency obligations for Systematic Internalisers on non-equity instruments, such quotes are no longer subject to transparency requirements.

Regarding post-trade transparency, the post-trade publication of transactions, both in the case of buy-side and sell-side, remains in charge of Systematic Internalisers until February 3rd 2025, date from which the same publication requirement has been assigned to entities recently introduced by the regulation under the title of Designated Publishing Entities (DPEs). Intesa Sanpaolo, having qualified as a DPE for all bond financial instruments (excluding ETCs and ETNs) as of February 3rd 2025, will continue to perform post-trade publication for the aforementioned financial instruments under the new role of Designated Publishing Entity.

 

 

 

 

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¹ This definition has been amended by Directive (EU) 2024/790, which requires national implementation by September 29, 2025. The MiFID amendments define a Systematic Internaliser as an investment firm which, on an organised, frequent and systematic basis, deals on own account in equity instruments by executing client orders outside a regulated market, an MTF or an OTF, without operating a multilateral system, or which opts in to the status of systematic internaliser.