The U.K.-EU Brexit deal provides no new transition period for financial services, nor any new arrangements to replace the existing “passport.” This leaves both the U.K. and EU to address matters of access in financial services through unilateral declarations of equivalence under existing equivalence regimes contained in U.K. and EU law (as well as any new ones that might be introduced) and through domestic laws. It does however address certain matters ancillary to equivalence, for instance on combatting money laundering and the application of global standards such as the Basel Rules. Unless there is a raft of unilateral equivalence declarations made by the EU before year end (to match thosealready made in the U.K.), it looks likely that for financial services 1 January will prove to be a “hard” Brexit, requiring implementation of most aspects of firms’ contingency plans.

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