The U.K. triggered Article 50 of the Treaty on the European Union in March 2017, setting in motion a two-year negotiation period over the terms of its departure from the E.U. As a result, private fund managers are left scrambling for solutions to replace the passporting rights upon which they currently rely to market their funds throughout the E.U. Fortunately, other European jurisdictions – such as Luxembourg, Germany and Ireland – have bolstered their infrastructures and processes to accommodate redomiciled funds and allow private fund managers to continue to access Europe. Each of these jurisdictions presents its own unique opportunities and challenges, however. These issues were analyzed in depth during the opening session of Dechert’s Global Alternative Funds Symposium. Moderated by Gus Black
, a London-based partner of the firm, the panel featured Joseph Glatt, general counsel, secretary and vice president of Apollo Capital Management; and Dechert partners Patrick Goebel
(Luxembourg), Jeff Mackey
(Dublin) and Hans Stamm
(Munich). This article
presents the key takeaways from the panel discussion. For more on re-domiciliation from the U.K. to the E.U., see “How ESMA’s Opinions on the Relocation of U.K. Financial Market Participants to the E.U. May Affect Fund Managers Post-Brexit
” (Nov. 16, 2017). For additional insights from Dechert attorneys, see our two-part series on navigating Europe post-Brexit: “Cross-Border Marketing Options and the Viability of Domiciling Funds in Luxembourg
” (Nov. 10, 2016); and “Domiciling Funds in Germany or Ireland to Access the E.U. Post-Brexit, the Possible Introduction of PRIIPs and the Rising Prominence of UCITS Structures
” (Nov. 17, 2016).
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