For those in financial services, the last few days have been long ones. The unexpected vote to Brexit will mean a prolonged period of uncertainty, lasting for at least the duration of the UK’s exit negotiations and beyond.

FCA issued a statement on 25 June (see here: FCA Statement) that says, as expected, that nothing changes during that period – existing regulations remain in force, and planned regulations remain planned. Any changes to either of these will depend on the UK government’s negotiations with the EU.

The next few years pose greatest uncertainty for those firms who have hitherto benefitted from access to EU markets via a MiFID passport. Whilst the shape of post-Brexit financial services remains uncertain and will be subject to negotiation, it must be the case that this access is under threat.

In our March Newsletter (see here: Fulcrum Compliance – March Newsletter) we advised eligible firms to apply for such passports now, whilst they are still available. That remains our advice.

Even though in the long term such passports may be withdrawn, it will be better to have one now as the negotiating parties will have to at least consider the position of firms with existing rights of access – even if they decide to ignore them. Firms with no such rights will not be a subject of these discussions.

We will continue to monitor the impact of Brexit as it evolves. Should you wish to discuss the implications for your firm, do contact us.


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