Whether the United Kingdom leaves the European Union on 29 March
2019 without a withdrawal agreement (a no-deal scenario) or whether
there is an orderly exit with a withdrawal agreement in place, the
UK will become a "third country" under EU law and will
therefore lose the passporting rights available to UCITS, UCITS
management companies and alternative investment fund managers
("AIFMs") under EU legislation. We
have been advising our clients on the implementation of their
Brexit contingency plans, including advising on the establishment
and authorisation of UCITS management companies, AIFMs and Super
ManCos (that is, management companies with an authorisation under
both the UCITS Directive and the Alternative Investment Fund
Managers Directive ("AIFMD")) in
Ireland, including in many cases obtaining an additional individual
portfolio management ("IPM")
authorisation. An alternative to establishing a management
company is to appoint a third party management company
