Cryptoassets are traded on a global basis. Indeed, the markets are even more global and constant than markets in more conventional financial instruments, rivalled only perhaps by the FX markets in their reach.

The European Commission has published draft legislative proposals which would require large non-EU banking firms with EU operations to establish an intermediate holding company in the EU. The proposed rules are similar to US requirements for certain non-US banking organizations to establish an intermediate holding company in the US. This note discusses the impact of the proposals on foreign banking groups and their restructuring plans, with a particular reference to US banks. It also considers the UK’s position in light of Brexit.

Introduction