Hard Brexit Impact Analysis

Page 30 of 106 Category If no agreement is reached: Consequence EU Document Finance Banking services CONTRACTS: As of the withdrawal date , the EU rules on conflicts of laws and jurisdictions will no longer apply to the United Kingdom. Where contracts are governed by the law of the United Kingdom, or contain a choice of law or an agreement in favour of the jurisdiction of a court in the United Kingdom, parties to those contracts should carefully assess the impact of the withdrawal of the United Kingdom on the validity and enforceability of those contracts and mitigate any risks, including any risks to their clients. Irish residents with banking contracts with UK established banks should examine their contracts to ensure they are compliant with EU law after the UK withdraws from the EU. WITHDRAWAL OF THE UNITED KINGDOM AND EU RULES IN THE FIELD OF BANKING AND PAYMENT SERVICES Finance Insurance As of the withdrawal date, the EU rules in the field of insurance / reinsurance, setting out the framework governing the activities of insurance / reinsurance undertakings across the EU, the protection of policyholders and the distribution of insurance products no longer apply to the United Kingdom. Check where insurance policies are issued from because people or businesses with Insurance contracts issued by UK established companies will no longer enjoy the same protection rights as contracts issues in Ireland or the EU. WITHDRAWAL OF THE UNITED KINGDOM AND EU RULES IN THE FIELD OF INSURANCE / REINSURANCE Finance Insurance Service Provision: As of the withdrawal date UK insurance undertakings will no longer benefit from the Solvency II authorisation to provide services in the Union (they will lose the so-called "EU passport") and will be third-country insurance undertakings. This means that those insurance undertakings will no longer be allowed to provide services in the EU, including through online sales, on the basis of their current authorisations. WITHDRAWAL OF THE UNITED KINGDOM AND EU RULES IN THE FIELD OF INSURANCE / REINSURANCE Finance Insurance Insurance Branches: As of the withdrawal date , Branches of UK insurance undertakings in the EU will be branches of third country insurance undertakings. They will need an authorisation in the Member State of their activity to be able to continue to do business and have to comply with the EU conditions. Authorisation of a branch however does not grant the right to conduct business across the EU Member States, but only in the Member States that has granted the authorisation. WITHDRAWAL OF THE UNITED KINGDOM AND EU RULES IN THE FIELD OF INSURANCE / REINSURANCE