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The Uncertain Consequences of Brexit for UK-Based Financial Services

Nicholas Sowels
p. 195-211

Résumé

The impact of Brexit on UK-based financial services is highly complex and uncertain to predict. At the time of writing (November 2017), the British government’s stated policy is to exit the EU, the Single Market and the Customs’ Union. Such hard Brexit will mean that UK-based financial companies will lose their “passporting” rights to operate in the rest of the EU. This will take some adjustment, especially for smaller players. Larger firms, however, are likely to be able to reorganise their business, albeit at some cost. Given the importance of finance to the functioning of market economies and the lobbying power of financial services firms, I conclude that the finance as a whole will navigate Brexit relatively smoothly.

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Texte intégral

Introduction

1Brexit is likely to have complex and as-yet unknown consequences for financial services produced in the UK. While few doubt that London will continue to be a major global financial centre, Brexit may well see some business move away from the UK. At the same time, the costs of financial services for the rest of Europe will rise.

  • 1 May, T., Speech: The government's negotiating objectives for exiting the EU, 17 January 2017.

2The exact nature of Brexit is hard to forecast. The government’s official position set out in January 2017 states that the UK will leave both the Customs Union and the Single Market when it leaves the EU at the end of March 2019. In place of the existing links with the EU, Theresa May asserted that Britain wants to be a “best friend and neighbour to [its] European partners”.1

  • 2 May, T, Florence speech: a new era of cooperation and partnership between the UK and the EU, 22 Sep (...)
  • 3 Bundesverband der Deutsche Industrie e.V. (BDI), „BDI schaut mit Sorge auf den Fortgang der Austrit (...)

3In September 2017 in her Florence speech, Theresa May proposed that negotiations between the UK and the EU continue for a fixed time period after March 2019, so that a bespoke trade and economic relationship can be negotiated in detail : the British government subsequently agreed to place a two-year limit on this transition/implementation phase.2 But, there are serious doubts about whether this is actually possible : given the contradictory demands of the UK and the ensuing lack of a post-Brexit strategy, there is a real danger of the UK sliding towards “very hard Brexit”. This is what the German employers’ confederation, for example, is envisaging.3

  • 4 Jenkins, P., “Banking on a back-to-back Brexit”, The Financial Times, November 3, 2017.
  • 5 House of Lords EU Financial Affairs Sub-Committee (oral evidence), Wednesday 1 November 2017 Meetin (...)

4In the financial sector, it is presently very difficult to predict what will occur. Leaving the Single Market means that financial institutions operating out of the UK will lose their “passporting rights” : i.e. the ability to operate throughout the EU based on their accreditation in Britain. The loss of these rights will have varied consequences across financial services. Some actors now seem quite sanguine about the future, such as the Swiss bank UBS which in early November 2017 indicated it would only move 250 persons into the other EU locations.4 By contrast, when testifying to the House of Lords a few days earlier, deputy governor of the Bank of England, Sam Woods, reckoned that 10,000 jobs could go on “day 1” after Brexit, while job losses over the longer term could be considerably higher (see below).5

5Given such uncertainties, this article can only look at a limited number of issues. Section 1 therefore examines briefly the question of “equivalence” access to the Single Market. The next section will provide some indication of how financial institutions are planning for Brexit and the possible job losses which may occur. Section 3 then examines how the political dynamics of trade negotiations between the UK and the EU may affect financial services. Specific reference is made to the issue of clearing euro-denominated derivatives which could possibly emerge as a flashpoint in the future relationship between Britain and the EU.

Aspects of the equivalence regimes

6If there is no bespoke trade deal between the UK and the EU, then trade and commercial relations between the two parties will operate under WTO guidelines. This will mean tariffs being levied on EU imports from the UK and customs clearance. Tariff rates vary greatly : for cars the EU tariff is 10 % ; for food & agricultural products the rates are much higher, given the historically protectionist nature of the Common Agricultural Policy.

7Trade in services is significantly different in two main ways. On the one hand, digital technology means that many services today can be delivered instantaneously worldwide via the internet : there are no physical borders to slow up trade. On the other hand, WTO trade liberalisation is less developed than for manufactured goods. This stems from the fact that trade in services were only brought into the GATT process during the last completed negotiating round (the Uruguay Round which ran from 1986 to 1994). Due to the highly diversified nature of services (including public services), the liberalisation process of service sector trade is less complete than for goods trade. In particular, regulations, national professional qualifications and public accreditation schemes, together with public procurement practices, etc. may constitute considerable non-tariff barriers to trade in services.

8In terms of banking and finance, this means that services provided by UK-based companies will need to meet the so-called “equivalence” requirements of the European Union. Equivalence here generally concerns businesses from third party countries (WTO members) which can carry out certain financial operations in the European Union as long as their home regulatory regimes are deemed to be equivalent to EU standards.

9British-based financial services will obviously meet this criterion when the UK exits the EU, for the very simple reason that the British government is planning to retain the acquis communautaires on leaving the Union. In the short run, there should be no problem therefore with having equivalence accepted, in those areas where it is indeed granted by the Union.

10Over the longer term, things could change as British and EU financial regulation may well diverge. It is too early to speculate about this, but UK regulation may well become less important than EU regulation over time, given the historical tendency for the UK to promote liberalised finance. A caveat to this is the fact that international agreements have been shaping financial regulation since the 2007-2008 crisis : specifically the G20 process put in place in the aftermath of the crisis has set out a number of principles for the re-regulation of financial activities, and these have been complemented by the Basel III agreement which has raised the capital requirements for banks. This international framework should continue to shape overall financial regulation, at least for the foreseeable future (although it is possible that the Trump administration will break up such cooperation).

  • 6 Bailey, A., (CEO, FCA), Letter to the Rt Hon Andrew Tyrie, Chairman of the Treasury Committee House (...)

11The impact of losing passporting and moving to equivalence regulation will vary significantly between financial services, and also between market players. According to the Financial Conduct Authority (FCA), there were some 5,476 UK-based firms benefitting from some form of passporting rights in mid-2016. Given that many firms supply several different types of financial services, the FCA calculated that the total number of (“outbound”) passports for these firms was 336,421 : the equivalent figures for foreign companies operating within Britain were 8,008 firms benefitting from 23,532 (“inbound”) passports.6 Converting all passports into accreditation under the equivalence regime will surely involve quite a substantial amount of administrative work – by firms and by regulators.

12Furthermore, EU legislation does not provide equivalence for all financial services. The Table provides a very short summary of different types of financial services and whether they are eligible for “equivalence” and “market access” once the UK leaves the single market.

Table : Key equivalence clauses in of EU financial legislation

Table : Key equivalence clauses in of EU financial legislation

Key : (-) not available ; ■ available ; □ partially available.

Source : Directorate-General for Internal Policies, Policy Department Economic and Scientific Policy A, Economic and Monetary Affairs, Implications of Brexit on EU Financial Services ; Study for the ECON Committee, IP/A/ECON/2016-22, PE 602.058, June 2017, p54.

13What stands out is that conventional banking services (be they retail services for small customers or wholesale commercial banking services for large customers) will not have market access to the EU, under the the EU’s Capital Requirements Directive (CRD IV) and Regulation (CRR). Similarly, investment services for retail customers (regulated by the EU’s Markets in Financial Instruments Directive and Regulation (MiFID II and MiFIR) will no longer have access to the European market. The same is true for investment funds regulated by the EU’s Undertakings for Collective Investment in Transferable Securities Directive 2009 (or UCITSD). Insurance will be the other major activity to be affected by the loss of passporting, under the EU’s Solvency II Directive, although re-insurance services will continue to have access to the EU market.

14Asset management activities conducted by hedge funds and private equity companies on the other hand will still have market access under the EU’s Alternative Investment Fund Managers Directive (AIFMD).

15Significantly, operators providing market infrastructure (including stock exchanges, etc.) and in particular clearing houses known as central counterparties (CCPs) can all obtain equivalence and market access. This is especially important concerning the trading of shares by European companies listed on the London stock exchanges and for the trading in euro-denominated derivatives : the latter is a potentially contentious issue which is further discussed below.

Job losses and company strategies

  • 7 WYMAN Oliver, “The Impact of the UK’s exit from the EU on the UK-based financial services sector”, (...)

16Figures on possible job losses resulting from Brexit and the end to passporting have been varied. A key estimate, which has become a reference, was given by the consulting company Oliver Wyman in late 2016. It suggests that 31-35,000 jobs could be at risk if around 40-50 % of EU related activity leaves London (under the WTO scenario). These are direct job losses, which could be compounded by falls in employment of 34-40,000 as London’s “ecosystem” as a financial services sector is impacted in general. The corresponding direct earnings losses were estimated to be approximately £ 18-20 billion, plus a further £ 14-18 billion in lost revenues for the ecosystem.7

  • 8 Ibid, Sam Woods, evidence to the House of Lords EU Financial Affairs Sub-Committee.

17In evidence given to the House of Lords in November 2017, deputy governor of the Bank of England, Sam Woods, stated that in terms of the long term impact of Brexit, the Oliver Wyman figures were within “the plausible range” of scenarios. At the same time, he indicated that a short term effect – a “day 1” movement – of job-losses could be about 10,000 : this figure is based on analyses of contingency plans by banks and insurance companies which the Bank of England had been able to see. Putting this in context, Mr Woods noted that it was less than 1 % of all jobs in Britain’s financial service sector.8

  • 9 Arnold, M. and McLannahan, B., “US bankers hatch two-stage Brexit plan for City”, The Financial Tim (...)

18A cursory review of company strategies for responding to Brexit provides a similarly mixed picture. Reports of early planning at the start of 2017 – at the time the government was declaring its position of leaving the single market – suggested that while significant numbers of jobs could well leave the UK over the long term, US banks operating in London were working on a “two-stage Brexit plan”. Such a strategy would allow them to avoid substantial moves of jobs out of London in the short term, while they were waiting to see what the final trade and finance agreements reached between the UK and the EU would be. Over the longer run, however, a leading US banker like Jamie Dimon (CEO of JP Morgan) has repeatedly stated that up to 4,000 out of a total 16,000 jobs in the UK (not just in London) could be relocated.9

  • 10 Arnold, M., “UBS warns on ‘significant’ shift out of UK by March”, The Financial Times, September 2 (...)
  • 11 Noonan, L. and Atkins, R., “UBS to move fewer London jobs than initially feared”, The Financial Tim (...)

19Paradoxically, as the uncertainties over Brexit have dragged on, and as the risks of disorderly Brexit seemed to be mounting by November 2017, contingency planning by banks appears to be becoming increasingly flexible. New techniques are emerging to avoid substantial and costly transfers of activities, at least in the short term. Thus, for example, the Swiss bank UBS, which has 5,000 persons operating in London, first announced that it would be shifting up to 1,000 staff from London.10 By the end of October 2017, however, the bank had scaled back its forecasts, indicating that as few as 250 people would be relocated. This change in strategy results from the hope that the bank will still be able to use its London operations for back office work : more specifically the idea is to “book its trades ‘back to back’ in London and another EU location”, whereby trades booked in the EU entity are offset in the bank’s London entity which will remain responsible for managing risks.11

  • 12 Donnellan, A., “Wall Street braced for ‘disorderly Brexit’, warns City”, The Sunday Times, 12 Novem (...)
  • 13 Dunkley, E., Binham, C., Arnold, M. and Noonan, L., "US banks’ ‘stop gap’ Brexit plans set to retai (...)

20Similarly, while the City of London Corporation has warned the government that “Wall Street bosses and policymakers in New York and Washington” were increasingly concerned about a “disorderly Brexit”,12 leading US financial institutions are formulating strategies to limit immediate employment relocation. “Stop gap” measures are being planned by banks like Morgan Stanley, Citigroup and Bank of America, in which they will use the London branches of their EU subsidiaries [sic] to smooth the transition process. This so-called “branch back” option is “essentially a reversal of the current set-up, where US banks tend to use their London operations to ‘passport’ their services across the rest of the EU”. It partly reflects the fact that finding staff in investment banking in the rest of the EU is difficult.13

  • 14 Davies, R., “France steps up effort to woo London banks planning Brexit move”, The Guardian, 7 July (...)
  • 15 Noonan, L., “EBA shift expected to weaken UK role in regulation”, The Financial Times, November 21, (...)
  • 16 Jenkins, P., “Are banks in the UK en marche to Paris?”, The Financial Times, July 12, 2017.
  • 17 Keohane, D., “Goldman Sachs confirms Frankfurt and Paris hubs after Brexit”, The Financial Times, N (...)
  • 18 Cox, J., “Lloyd Blankfein: Goldman Sachs CEO takes to Twitter to hint at Brexit job moves to Frankf (...)
  • 19 Bray, C., “Bank of America Chooses Dublin as Post-‘Brexit’ European Hub”, The New York Times, July (...)
  • 20 Ibid.
  • 21 Noonan, L., “Citigroup picks Luxembourg for EU private banking hub”, The Financial Times, October 1 (...)

21Such stop gap measures and the wait-and-see attitude of the banks is logical given the state of uncertainty prevailing over the Brexit negotiations in November 2017. It perhaps also reflects the fact that finding clear alternatives to London as a location in the EU has so far not been that easy. Numerous cities are vying to capture business from London. The French government has formulated a set of policy proposals to attract business to Paris. These include abolishing the top tax bracket of a payroll tax on salaried employees, excluding bonuses in labour court decisions on unfair dismissal and even setting up an international tribunal in Paris that can handle cases in English.14 Paris benefits too from being Europe’s other major capital and cultural centre, alongside London. Finally, at the end of November 2017 it was announced that the European Banking Authority will be moving there, after leaving London in the wake of Brexit. This will give a boost to the French capital in its role in financial regulation.15 So far, however, only the British bank HSBC has repeatedly stated that it could shift 1,000 jobs to the French capital16, although Goldman Sachs has said it was creating a second European hub in Paris, alongside Frankfurt.17 Other lead contenders for attracting business are Frankfurt and Dublin. The former city is of course the financial centre of Europe’s largest economy and the home of the European Central Bank. Its position as an alternative to London was given a public boost when Lloyd Blankfein, the CEO of Goldman Sachs, very ostensibly Tweeted in October 2017 : “Just left Frankfurt. Great meetings, great weather, really enjoyed it. Good, because I’ll be spending a lot more time there. #Brexit”.18 Meanwhile, in July 2017, Bank of America declared that it had chosen Dublin as its future European Union hub. The Irish capital offers advantages in terms of the use of English and a common law legal system for drafting international contracts.19 Citigroup has also announced that it will be opening a second trading hub in Frankfurt,20 while setting up a new booking centre for its private banking activities in Luxembourg.21 And so on …

The regulators and the negotiations

22The fluidity and inventiveness that seem to be characterising the reorganisation of banking (and other financial) operations by major (foreign) players suggests that while Brexit may be disruptive to UK and European financial services, this is one economic activity that could well handle hard Brexit, at least in the short term. There are however a number of conditions to this. These revolve notably on the degree of cooperation that characterises future negotiations between the UK and the EU concerning some sort of future trade deal, as well as the flexibility and cooperation shown specifically by financial regulators in the UK and in the EU. Here there are reasons for hope and concern.

  • 22 Rankin, J., “EU negotiator wants ‘special’ deal over access to City post-Brexit”, The Guardian, 13 (...)
  • 23 Barnier, M., Speech by Michel Barnier at “The Future of the EU Conference”, 20 November 2017, < htt (...)

23Finance is in some ways different to other economic activities, as it is absolutely essential to the operation of all other economic activities in any complex society, given that it organises the flow of money without which transactions and exchange are impossible. If the financial system breaks down, as nearly happened after the collapse of Lehman Brothers in September 2008, it risks leading to a sudden stop of all business. Financial stability is therefore vital to the operation of the real economy, and full care needs to be taken by all parties to ensure that Brexit does not entail significant financial instability. As the EU Commissioner responsible for re-regulating finance within the Union in the wake of the financial crisis, Michel Barnier is well placed to be aware of these risks. This likely explains the views he expressed in a private meeting to MEPs in January 2017, when he reportedly said that “[t]here will be a special/specific relationship. There will need to be work outside of the negotiation box… in order to avoid instability”.22 That said, in a speech in November 2017 at the Centre for European Reform, Mr Barnier clearly stated that there can be no “cherry picking” concerning the Single Market, and that this clearly concerns financial services too.23

  • 24 Foley, S., “What price the new democracy? Goldman Sachs conquers Europe”, The Independent, 18 Novem (...)
  • 25 OECD, Expert Group on Conflict of Interest, Revolving Doors, Accountability and Transparency – Emer (...)
  • 26 Chavagneux, C. et Philipponnat, T., La capture : où l’on verra comment les intérêts financiers ont (...)
  • 27 Mervyn, K., The End of Alchemy: Money, Banking and the Future of the Global Economy, London, Little (...)

24Directly linked to the centrality of finance to economic activity and to the incredible economic resources which finance commands is the ability of the sector as a whole to shape the policy-making process. You do not have to be an adept of conspiracy theories to observe the influence of Goldman Sachs within the political and regulatory establishment,24 or to see that government has been greatly captured by the industry. Whether it is the “revolving door” between the sector and government,25 purchasing direct influence with politicians or more generally shaping the policy-making mindset, finance has managed to constrain post-crisis policy to suit its own interests to a large degree.26 Even an insider’s insider like Lord Mervyn King, the former Governor of the Bank of England, has clearly noted that although there has been much re-regulation of finance since the crisis, there has been very little structural change in how the global financial system operates.27

  • 28 ECB, “Brexit: an ECB supervision perspective”, Newsletter, 15 November 2017, <https://www.bankingsu (...)

25The central role of finance in capitalist economies along with its massive political power should allow the sector to massage several regulatory issues which hard Brexit is throwing up. For example, the current strategies for “back to back” booking or “branch back” banking described above will need to get clearance from EU regulators, who may resist efforts by banks to keep staff – and bank capital – in London while expanding business actually located in Europe : indeed the ECB has already warned that operations set up in the EU after Brexit cannot be “empty shells” or “letter box banks”.28 Similarly, hard Brexit will require the British authorities – mainly the Bank of England – to grant licences to the 75 European banks and 85 insurance companies operating in the UK after Brexit. According to Sam Woods, this will require time – between 12 and 18 months – and could be a problem if there is no transition period after March 2019. But in my opinion, it likely that such difficulties will be ironed out.

  • 29 European Securities and Markets Authority.
  • 30 European Insurance and Occupational Pensions Authority.
  • 31 Howard Davies (Chairman of the Royal Bank of Scotland), “Post-Brexit financial regulation cannot be (...)

26A more tricky issue concerns the future cooperation between British and European regulators. Since the financial crisis, regulation across the globe has followed international guidelines established within the G20 and by the Basel Committee on Banking Supervision. Given London’s position in global financial markets, the British authorities have played a lead role in implementing such re-regulation in Europe. By leaving the EU and the Single Market, British regulators will also be leaving European supervision authorities. These include the European Banking Authority (see above), Esma29 (that oversees securities markets) and EIOPA30 (which is responsible for insurance and pensions). Also, the governor of the Bank of England will no longer sit on the European Systemic Risk Board at the ECB, where he is currently vice-chairman.31 It is in the interests of all parties that some forms of future cooperation continue, enforcing the international regulatory process. But how this will be done remains to be seen, and could even become particularly difficult in the event of a confrontational form of Brexit leading to competitive deregulation by the UK.

  • 32 Treanor, J., “London could lose out as ECB seeks control of euro clearing after Brexit”, The Guardi (...)

27A particular flashpoint in future negotiations between the UK and its European partners could stem from the location of derivative trading denominated in Euros. This business is currently largely conducted in London, and has a daily turnover of about € 1 trillion.32 Since the financial crisis and international re-regulation, trading in many standardised derivatives now has to take place in regulated market places, and cleared through central counterparties (CCPs). These organisations, such as the London Clearing House (LCH) of the London Stock Exchange, act as intermediaries between the two parties of any derivative transaction, and the CCPs guarantee the transaction in case one of the original parties cannot honour the trade. This function is facilitated and made cheaper by economies of scale : the more transactions cleared through a CCP, the lower the costs per transaction conducted in the market place and the lower the relative costs of a failed transaction. Having this activity concentrated in London therefore provides benefits for businesses throughout Europe wishing or needing to trade in derivatives.

  • 33 Stafford, P., “Key questions for City over post-Brexit euro clearing”, The Financial Times, May 2, (...)
  • 34 Barker, A. and Stafford, P., Victory of UK over Eurozone clearing houses, The Financial Times, Marc (...)
  • 35 ECB Press release, “ECB recommends amending Article 22 of its Statute, 23 June 2017, at <https://ww (...)
  • 36 Stafford, P., “Deutsche Börse eyes City of London’s euro clearing crown”, The Financial Times, Nove (...)

28At the same time, there are some legitimate concerns by EU regulators – notably the ECB – that the continuation of such trading outside the EU will raise problems of regulation and possibly public intervention in case of difficulties. There were concerns by the ECB in 2011, for example, that the LCH had raised margins on Irish and Portuguese government bonds,33 possibly aggravating Europe’s sovereign debt crisis. The ECB’s push at the time to bring such clearing into the Eurozone was rejected by the European Court of Justice in 2015.34 With the UK leaving the EU, however, this issue has been reopened, and in June 2017, the ECB’s Governing Council recommended a change in the Bank’s Statute in order to provide the ECB with clear legal competence in the area of central clearing.35 Moreover, other European market places may also want to capture business from London. It is notable, for example, that Deutsche Börse has teamed up with 20 banks (including Barclays, Citadel Securities, UBS, HSBC and ABN Amro) to capture clearing of euro-denominated swaps from Britain. Significantly, it is drawing on the business model of the LCH whereby participating banks are profit-sharers in the project.36

  • 37 Fleming, S., “Post-crisis rules creating huge financial firms, warns Cohn”, The Financial Times, Oc (...)
  • 38 Coffee, J. C., “How should the EU respond to Bexit and Trump?: the lessons from trade wars”, paper (...)

29Such official moves entail a number of risks. Firstly, heavy-handed action could be destabilising for the operation of markets and this alone could lead to problems of financial market instability. Off-setting this problem is the fact that huge CCPs have recently been criticised by Gary Cohn (no less than the director of President Trump’ National Economic Council) as being too big and as a potential source of financial instability.37 Second, a shift of business out of the large London markets will surely raise costs for European business needing to take derivative positions. Economies of scale in Europe will be lower, and so costs to clients will be higher. Thirdly and perhaps most importantly, deliberate moves by EU regulators and Europe’s financial services providers to capture euro-denominated derivatives trading could provoke retaliation by British regulators and UK-based financial institutions. It could, in a worst case scenario, lead to a trade war, if Britain retaliates for example by reducing financial regulation and taxation. Such confrontation over finance, which is a strategic economic activity for the UK, could spill over into the rest of the Brexit/post-Brexit process. History indicates that trade wars can develop rapidly and have substantial consequences.38

Conclusion

30The impact of Brexit on UK-based financial services is set to be highly complex, and it is difficult to make predictions about how events will unfold. It is important not to view such services as homogenous, and the consequences of Brexit will vary across activities and financial services companies.

31Given the key importance of finance in the function of market economies, regulators in the EU and the UK are likely to want to limit the damage of Brexit as much as possible. They will almost certainly be under pressure to do so from market operators as well, given the unparalleled lobbying power of finance.

32Moreover, if there is one sector which has the resources to adjust to Brexit, it is surely finance. Information released by major financial services firms suggests that they are planning for all eventualities in a highly flexible manner. Brexit will entail costs, but business will go on, and the London market will surely maintain its international position, even if some activity is chipped away at the edges.

33That said, there are some risks, in particular if a tug-of-war takes place about the location of euro-denominated derivatives trading. This has the potential, if not handled well, to lead to considerable acrimony in future negotiations about a trade deal between the UK and the EU.

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Notes

1 May, T., Speech: The government's negotiating objectives for exiting the EU, 17 January 2017.

2 May, T, Florence speech: a new era of cooperation and partnership between the UK and the EU, 22 September 2017.

3 Bundesverband der Deutsche Industrie e.V. (BDI), „BDI schaut mit Sorge auf den Fortgang der Austrittsverhandlungen“, Pressemitteilung, 26/2017, 5 October 2017.

4 Jenkins, P., “Banking on a back-to-back Brexit”, The Financial Times, November 3, 2017.

5 House of Lords EU Financial Affairs Sub-Committee (oral evidence), Wednesday 1 November 2017 Meeting started at 10.16am, ended 12.28pm, <http://www.parliamentlive.tv/Event/Index/bb4b3aff-64db-47bf-9def-712d466cc498>, [10 November 2017].

6 Bailey, A., (CEO, FCA), Letter to the Rt Hon Andrew Tyrie, Chairman of the Treasury Committee House of Commons, 17 August 2016, <https://www.parliament.uk/documents/commons-committees/treasury/Correspondence/AJB-to-Andrew-Tyrie-Passporting.PDF>, [19 November 2017].

7 WYMAN Oliver, “The Impact of the UK’s exit from the EU on the UK-based financial services sector”, October 2016, < http://www.oliverwyman.com/content/dam/oliver-wyman/global/en/2016/oct/Brexit_POV.PDF>, [14 November 2017].

8 Ibid, Sam Woods, evidence to the House of Lords EU Financial Affairs Sub-Committee.

9 Arnold, M. and McLannahan, B., “US bankers hatch two-stage Brexit plan for City”, The Financial Times, January 19, 2017.

10 Arnold, M., “UBS warns on ‘significant’ shift out of UK by March”, The Financial Times, September 26, 2017.

11 Noonan, L. and Atkins, R., “UBS to move fewer London jobs than initially feared”, The Financial Times, October 29, 2017.

12 Donnellan, A., “Wall Street braced for ‘disorderly Brexit’, warns City”, The Sunday Times, 12 November 2017.

13 Dunkley, E., Binham, C., Arnold, M. and Noonan, L., "US banks’ ‘stop gap’ Brexit plans set to retain London jobs", The Financial Times, November 12, 2017.

14 Davies, R., “France steps up effort to woo London banks planning Brexit move”, The Guardian, 7 July 2017.

15 Noonan, L., “EBA shift expected to weaken UK role in regulation”, The Financial Times, November 21, 2017.

16 Jenkins, P., “Are banks in the UK en marche to Paris?”, The Financial Times, July 12, 2017.

17 Keohane, D., “Goldman Sachs confirms Frankfurt and Paris hubs after Brexit”, The Financial Times, November 20, 2017.

18 Cox, J., “Lloyd Blankfein: Goldman Sachs CEO takes to Twitter to hint at Brexit job moves to Frankfurt”, The Independent, 19 October 2017.

19 Bray, C., “Bank of America Chooses Dublin as Post-‘Brexit’ European Hub”, The New York Times, July 21, 2017.

20 Ibid.

21 Noonan, L., “Citigroup picks Luxembourg for EU private banking hub”, The Financial Times, October 12, 2017.

22 Rankin, J., “EU negotiator wants ‘special’ deal over access to City post-Brexit”, The Guardian, 13 January 2017.

23 Barnier, M., Speech by Michel Barnier at “The Future of the EU Conference”, 20 November 2017, < http://www.cer.eu/in-the-press/speech-michel-barnier-future-eu-conference#comment-5374>, [22 November 2017].

24 Foley, S., “What price the new democracy? Goldman Sachs conquers Europe”, The Independent, 18 November 2011.

25 OECD, Expert Group on Conflict of Interest, Revolving Doors, Accountability and Transparency – Emerging Regulatory Concerns and Policy Solutions in the Financial Crisis, GOV/PGC/ETH(2009)2, 28-Apr-2009, <http://www.oecd.org/officialdocuments/publicdisplaydocumentpdf/?cote=GOV/PGC/ETH(2009)2&docLanguage=En>, [14 November 2017].

26 Chavagneux, C. et Philipponnat, T., La capture : où l’on verra comment les intérêts financiers ont pris le pas sur l’intérêt général et comment mettre fin à cette situation, Paris, La Découverte, 2014.

27 Mervyn, K., The End of Alchemy: Money, Banking and the Future of the Global Economy, London, Little Brown, 2016, pp 40-41.

28 ECB, “Brexit: an ECB supervision perspective”, Newsletter, 15 November 2017, <https://www.bankingsupervision.europa.eu/press/publications/newsletter/2017/html/ssm.nl171115_2.en.html>, [18 November 2017].

29 European Securities and Markets Authority.

30 European Insurance and Occupational Pensions Authority.

31 Howard Davies (Chairman of the Royal Bank of Scotland), “Post-Brexit financial regulation cannot be left to negotiators”, The Financial Times, October 31, 2017.

32 Treanor, J., “London could lose out as ECB seeks control of euro clearing after Brexit”, The Guardian, 23 June 2017.

33 Stafford, P., “Key questions for City over post-Brexit euro clearing”, The Financial Times, May 2, 2017.

34 Barker, A. and Stafford, P., Victory of UK over Eurozone clearing houses, The Financial Times, March 4, 2015.

35 ECB Press release, “ECB recommends amending Article 22 of its Statute, 23 June 2017, at <https://www.ecb.europa.eu/press/pr/date/2017/html/ecb.pr170623.en.html >, [15 November 2017].

36 Stafford, P., “Deutsche Börse eyes City of London’s euro clearing crown”, The Financial Times, November 20, 2017.

37 Fleming, S., “Post-crisis rules creating huge financial firms, warns Cohn”, The Financial Times, October 15, 2017.

38 Coffee, J. C., “How should the EU respond to Bexit and Trump?: the lessons from trade wars”, paper prepared for the Public Authority and Finance Conference organised by LaBex ReFi and co-sponsored by the Columbia Center on Corporate Governance in Paris, September 1-2, 2017.

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Table des illustrations

Titre Table : Key equivalence clauses in of EU financial legislation
Légende Key : (-) not available ; ■ available ; □ partially available.
Crédits Source : Directorate-General for Internal Policies, Policy Department Economic and Scientific Policy A, Economic and Monetary Affairs, Implications of Brexit on EU Financial Services ; Study for the ECON Committee, IP/A/ECON/2016-22, PE 602.058, June 2017, p54.
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Nicholas Sowels, « The Uncertain Consequences of Brexit for UK-Based Financial Services », Observatoire de la société britannique, 21 | -1, 195-211.

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Nicholas Sowels, « The Uncertain Consequences of Brexit for UK-Based Financial Services », Observatoire de la société britannique [En ligne], 21 | 2018, mis en ligne le 01 novembre 2018, consulté le 18 novembre 2018. URL : http://journals.openedition.org/osb/2294 ; DOI : 10.4000/osb.2294

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Nicholas Sowels

Maître de Conférences en Civilisation britannique à l'Université de Paris 1

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