UK firms and funds which conduct business in the European Economic Area (EEA) and European firms and funds based in the EEA and which rely on passporting to carry out business in the UK should consider if or how they will be affected by Brexit and their potential options. To help firms consider whether Brexit might affect their business the FCA has published a useful Checklist.
Temporary Permissions Regime
The UK Government have stated that they will, if necessary, introduce a temporary permissions regime for inbound passporting EEA firms and funds. This means that if the passporting regime abruptly ends the temporary permissions regime will allow firms and funds to continue to conduct business and market their services in the UK within the scope of their existing permissions whilst they seek full UK authorisation. To help firms, the FCA have published their approach to the temporary permissions regime.
The UK and EU have agreed the terms of an implementation period which would apply from the end of March 2019 to the end of December 2020 when EU law will still apply in the UK. However this implementation period is part of the withdrawal agreement and could, therefore, change.
How we can help UK firms
The FCA are preparing for a range of scenarios and firms are well advised to do likewise. This should include the possibility of the UK leaving the EU on 29 March 2019 without a withdrawal agreement and without the UK Government and the EU having ratified an implementation period.
Compliancy Services provide a range of consulting services and have helped number of Financial Services firms across different sectors consider their Brexit plan.
How we can help EEA firms
Compliancy Services offer a specialist award-winning FCA Authorisations service that has been honed while successfully managing over 1,100 authorisations. We know what the FCA is looking for and we're here to help you get authorised quickly and with a minimum of fuss.