Bottom Line

Brexit is currently scheduled to take effect on 1 January 2021. Undecided factors including whether a hard Brexit will occur and resulting impacts to regulated and unregulated financial service providers remain unsettled.

Trust Payments Immediate Impact

Trust Payments’ regulated entities (e.g., payments acquiring) are fully prepared for Brexit. Our regulated EU-based payments acquiring business, Trust Payments (Malta) Ltd, will allow us the advantage to seamlessly continue servicing our EU and UK acquiring customers. Notably, however, while the card schemes may have granted up to two years for affected companies to make necessary Brexit transitions, the UK authorities have made it clear that EU firms will only be allowed to continue servicing such clients as long as is necessary while they “seek full authorisation, if required.” This is referred to as the Temporary Permission Regime (TPR), which will start when the transition period ends after 2020. Accordingly, as a regulated EEA firm, Trust Payments (Malta) Ltd has timely notified the FCA of its intention to utilise the TPR and continue providing payment services in the UK after the end of the transition period.

Impacts to UK and EU Unregulated Businesses

Fully understanding the impacts to unregulated services (e.g., payments gateway, technological) provided by Trust Payments will depend on whether the UK and EU are able to agree upon a Free Trade Agreement (FTA). The FTA would likely take effect once the transition period ends. Still undetermined is whether and to what aspects of financial services will fall within the FTA’s scope. For instance, cross-region data privacy considerations may be needed even if an FTA is agreed in order to ensure continued compliant protection of personal data transferred between the EU and UK.

Next Steps

While the end of the transition period nears, there are remaining issues that will need to be addressed once further guidance is released by UK authorities. Accordingly, further Brexit developments will be closely monitored. Necessary steps will then be taken and further information will be released. 

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