Brexit ‘no deal’ WTO situation—implications for Financial Services
Produced in partnership with Tony Katz and Puesan Lam and Paul Hardy of DLA Piper
Brexit ‘no deal’ WTO situation—implications for Financial Services

The following Financial Services practice note Produced in partnership with Tony Katz and Puesan Lam and Paul Hardy of DLA Piper provides comprehensive and up to date legal information covering:

  • Brexit ‘no deal’ WTO situation—implications for Financial Services
  • The EU Single Market for Financial Services
  • The application of WTO rules to financial services
  • What practical steps should financial institutions take to prepare for a ‘no deal’ WTO situation?
  • UK steps towards withdrawal—the European Union (Withdrawal) Act 2018
  • Passporting rights
  • Third-country access and equivalence regime
  • Relocation or establishing an authorised subsidiary in another member state
  • Acting outside the regulatory 'perimeter'

BREXIT: 11pm (GMT) on 31 December 2020 (‘IP completion day’) marked the end of the Brexit transition/implementation period entered into following the UK’s withdrawal from the EU. Following IP completion day, key transitional arrangements come to an end and significant changes begin to take effect across the UK’s legal regime. This document contains guidance on subjects impacted by these changes. Before continuing your research, see: Brexit and financial services: materials on the post-Brexit UK/EU regulatory regime.

This Practice Note considers the impact on the UK financial services sector in the event of a ‘no deal’ World Trade Organization (WTO) Brexit outcome (where there is no deal between the EU and UK and the parties fall back on the WTO rules) and does not consider transitional provisions that may be put in place between the UK and European Economic Area (EEA).

The EU Single Market for Financial Services

Financial institutions (banks, investment firms, fund managers, insurers, insurance intermediaries, mortgage credit brokers, payment institutions and e-money issuers) across the EU benefit from the EU Single Market for Financial Services which is based on the principle of mutual recognition and harmonisation of standards.

One of the key features of the EU Single Market for Financial Services is the ‘European passport’. This allows financial institutions to carry out their activities across the EU without setting up a separate entity and/or obtaining separate authorisation in each

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