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On the Existence of a Pan-European Reverse Solicitation Regime Under MiFID II, and Its Importance on a ‘Hard’ Brexit

This client memorandum concerns a highly technical point of considerable practical importance. It challenges aspects of the received wisdom that, for post-Brexit cross-border investment business conducted from the U.K. into...more

More Pieces of the Brexit Puzzle: Enhanced Equivalence, Transitional Regimes

Many EU and U.K. financial institutions have been waiting with bated breath for (and commencing their contingency plans without) a clear picture of what post-Brexit U.K.-EU financial services will look like. In this note we...more

European Commission Confirms No Issue With Contract Continuity on a Hard Brexit

The European Commission today published a communication addressing the possible consequences of a hard Brexit. In it, they discuss the long-standing question of the continuity of contracts that straddle the Brexit date. This...more

Smoothing the Path for Financial Institutions on Brexit

The U.K.’s HM Treasury has set out its approach to the grandfathering of EU27 businesses on Brexit and to how existing EU financial services directives and regulations are to be adopted into U.K. law at the moment of Brexit...more

Brexit: The Great Repeal Bill

On 13 July 2017, the UK government published the European Union (Withdrawal) Bill, known as the “Great Repeal Bill.” This major piece of constitutional legislation sets out the government’s proposals for transforming existing...more

Implications for Non-EU Banking Groups of the EU’s New Intermediate Holding Company Proposals

The European Commission has published draft legislative proposals which would require large non-EU banking firms with EU operations to establish an intermediate holding company in the EU. The proposed rules are similar to US...more

Brexit: A Financial Free Zone Within the City

The UK Government recently indicated that it intends to negotiate a unique EU-UK relationship post-Brexit. It is hoped that the arrangements will be appropriate for the UK and London’s position as a leading international...more

Brexit and Equivalence: Review of the Financial Services Framework Across All Sectors

Since the UK voted to leave the EU on 23 June 2016, there has been much speculation about the form of the future access arrangements between the UK and the EU for financial institutions. In a scenario where no new deal is...more

Brexit Q&A: Business Implications

On Thursday 23 June 2016, the UK electorate voted to leave the European Union. While this vote was advisory in nature, we expect that ultimately the UK Government and Parliament will respect the outcome and serve notice to...more

Brexit: What Does the Vote Mean for Business?

Today, it was announced that the UK public has voted to leave the European Union. There will now be a negotiation of a new relationship between the UK and Europe. The fact of the vote itself has no legal effect on the laws of...more

Brexit: Options for and Impact of the Possible Alternatives to EU Membership

The UK is holding a referendum on 23 June 2016 to decide whether or not to remain a member of the European Union. There seems to be a disconnect between some aspects of public discourse on the vote and the actual effect of an...more

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