Background
Firms that have passports in place to provide services to clients in other EU member states have been receiving letters recently from regulators in some states emphasising that the passport arrangement will cease to be available on 29th March 2019. Thistle has seen examples of letters of this kind sent to our clients by the German regulator BaFIN and also by the French and Spanish regulators.
What will happen?
Unless a late agreement is reached by the UK Government, all outward passports will become unavailable on 29th March 2019, and firms will need to apply for direct authorisation in their chosen state if they wish to continue to provide services to clients based there. This is likely to be a lengthy and complex process.
If you are concerned about the implications of any of the issues raised in this update and would like advice or help, please contact Thistle on 020 7436 0630 or email info@thistleinitiatives.co.uk. Thistle can provide a full range of compliance services, including help with FCA, PRA or overseas regulator authorisation, advice on how to improve your systems and controls, past business and complaint handling reviews and remedial solutions.