On 23 June 2016, UK voters decided to leave the European Union (“EU”). While implementation of this decision will take years, financial institutions doing business in the UK and the rest of the EU, especially those that rely on the EU “passport” for financial services, must begin to assess now the impact of Brexit on their business models. There are a number of issues that financial institutions will face, but amongst the most important are the extent to which firms (i) based in the UK (including the UK subsidiaries of non-UK banks) will be able to access EU markets and (ii) based in the EU (outside the UK) will be able to access UK markets.

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