Introduction
On 24 December 2020, Michael Barnier, the European Union’s chief negotiator said, “The clock is no longer ticking”. Four and a half years after the Brexit referendum, the United Kingdom and the European Union had finally concluded a free trade and cooperation agreement (TCA) that provisionally
1 became applicable on 1 January 2021. From that date, UK asset managers and other financial services firms lost their passporting rights. These rights had broadly allowed UK-licensed firms to provide their services into the EU from the UK, and EU-licensed firms to provide their services into the UK from the EU. But what has taken their place?