It currently seems likely that “passporting,” that is the ability for, say, a UK subsidiary of a US firm, to provide services across the EU, will end. A possible alternative is “equivalence”, where the EU regulatory authorities allow non-EU firms (including potentially both the UK and the US) to provide limited services across the EU. If “equivalence” fails then US firms currently accessing the EU through the UK may have to think about establishing a new presence within the EU.
While many uncertainties remain, now is the time to start thing about contingencies. Our Consultants are well placed to help US firms analyze the possible scenarios and help with contingency planning both initially and as the final picture emerges.