"The difficulty of proving a client approached a third country firm for investment services “at their own exclusive initiative” means some non-European firms can bypass the payment for order flow ban under MiFID II, an expert has claimed. "The only way third country firms can get around the payment for order flow ban under MiFID II is if they can show the contact was exclusively initiated from the client,” financial regulation expert and author Seb Malik, told FOW on Wednesday." http://www.finregalert.com/expert-claims-payment-for-order-flow-loophole-in-mifid-ii/ That explains this: "However, this year we plan to move all CSUK accounts of U.K. and Switzerland residents to Charles Schwab & Co., Inc. (CS&Co)." "For clients residing in Austria, France, Ireland, Italy, the Netherlands, and Sweden. ... However, as a consequence of the Brexit process, we will not be opening new accounts as of March 15th, 2019 through CSUK." https://www.schwab.co.uk/public/schwab-uk-en/nn/brexit.html Schwab seems to currently accept new clients from Germany, Spain, UK and Switzerland. Maybe because new clients in these countries will board Schwab US?