however, it is equally certain that such a situation is not unrepresentative of the complex way in which financial institutions operate.

In principle, one could easily advance the argument that Brexit will have little or no impact at all on the SMRC, it is after all frequently touted as being the recent exception to the rule that EU law has shaped modern British finance law. In spite of this, it would be naïve to suggest that the tornado that is Brexit will have no tangible impact on the SMRC, irrespective of how independent and unique it is to domestic UK law. This problem has been mooted by commentators and legal experts. In a recent article in Financial News London, the scenario of banks relocating senior staff to EU countries (post-Brexit) was addressed, alongside the difficulties of attempting to enforce the Senior Managers Regime in an EU country post-Brexit. In the very same article, an employment partner at Allen & Overy suggested that UK regulators may have to scale back their regulatory ambitions post-Brexit, especially in-regard to non-UK resident senior managers if they’re relocated to a jurisdiction that British regulators feel is ‘suitably regulated’ by local authorities. There is no doubt that this represents a cogent and coherent argument that is difficult to refute. As a consequence of Britain’s long membership of the EU, the regulatory standards in Britain and other countries in the single market are, in many cases, standardised and complement each other. It is not difficult to envisage the FCA, who already find enforcement a challenge , finding it difficult to, and difficult to justify, enforcing SMRC regulatory standards in EU jurisdictions where, for the foreseeable future, they are so similar to British standards.

It is, therefore, entirely possible that, depending on the ultimate outcome of Brexit, deals are struck between the UK and EU/EEA member states, where regulatory standards are broadly similar, which w