全球風(fēng)險(xiǎn)管理專(zhuān)業(yè)人士協(xié)會(huì)(GARP)致力于為風(fēng)險(xiǎn)管理?xiàng)l線上的各級(jí)人員，包括各大金融機(jī)構(gòu)的風(fēng)險(xiǎn)從業(yè)者和監(jiān)管機(jī)構(gòu)人員提供風(fēng)險(xiǎn)教育和最新行業(yè)資訊。金程網(wǎng)校將持續(xù)轉(zhuǎn)載“GARP Risk Intelligence”系列文章，介紹科技、企業(yè)文化與治理、能源等領(lǐng)域?qū)Σ僮黠L(fēng)險(xiǎn)、信用風(fēng)險(xiǎn)、市場(chǎng)風(fēng)險(xiǎn)和資產(chǎn)負(fù)債管理的影響。讓我們一起全面認(rèn)識(shí)風(fēng)險(xiǎn)，防范風(fēng)險(xiǎn)，化解風(fēng)險(xiǎn)。
英國(guó)可能會(huì)在沒(méi)有平穩(wěn)過(guò)渡協(xié)議的情況下于3月29日離開(kāi)歐洲——當(dāng)下許多猜測(cè)都圍繞著這一可能性將帶來(lái)的后果展開(kāi)。沒(méi)有協(xié)議意味著英國(guó)將成為其最大貿(mào)易伙伴——歐盟的第三國(guó)。由于缺乏正式的自由貿(mào)易協(xié)定，英國(guó)和歐盟突然面臨需要轉(zhuǎn)而使用世界貿(mào)易組織規(guī)則的尷尬局面。
除了有限的臨時(shí)授權(quán)外，英國(guó)企業(yè)將面臨20多年前歐盟單一市場(chǎng)出現(xiàn)之前的許多類(lèi)似挑戰(zhàn)，以及自1973年英國(guó)加入歐盟以來(lái)它們?cè)僖参丛媾R的關(guān)稅壁壘和其他挑戰(zhàn)。
“這就是為什么至少兩年的過(guò)渡期非常重要，因?yàn)樗试S歐盟和英國(guó)在此期間就他們不想失去的一切達(dá)成一致，同時(shí)不破壞這些利益共同點(diǎn)，”多蘿西·列文斯頓解釋道。利文斯頓是知名的國(guó)際律所史密夫斐爾(Herbert Smith Freehills)英國(guó)退歐小組的領(lǐng)導(dǎo)人，也是倫敦金融城律師協(xié)會(huì)金融法委員會(huì)主席。她從貿(mào)易、運(yùn)輸、供應(yīng)鏈、口岸查驗(yàn)和型式批準(zhǔn)等多個(gè)方面闡述了英國(guó)無(wú)協(xié)議脫歐可能對(duì)實(shí)體經(jīng)濟(jì)造成的種種影響。
“不完美的局面”
“If we drop out suddenly and all these things fall away,” Livingston said, “we're left with an imperfect situation that definitely would risk substantial disruption to trade in both goods and services.”
Impeding the withdrawal agreement is the so-called Irish backstop. The provision was designed to prevent a “hard” border between Northern Ireland, a part of the U.K., and the Republic of Ireland, which will continue as an EU member. The U.K. government has been unable to garner sufficient support for the agreement from members of Parliament wary of lingering obligations to the EU, and continuing negotiations in London and with the EU have failed to break the impasse.
Recognizing the stakes, the U.K. last August published extensive instructions on preparing for a no-deal Brexit and has followed up with significant legislation. The European Commission (EC) launched a more streamlined “Contingency Action Plan” last November. On December 19, the EC stated that it had adopted all the legislative proposals and delegated acts announced in the action plan, and that any remaining items would be ready by February 15 “to allow for a vote in competent committees.”
引發(fā)實(shí)體經(jīng)濟(jì)風(fēng)險(xiǎn)
The financial services industry has received significant Brexit-related attention, given its business and economic importance. Livingston said that the U.K. has established a “temporary permissions regime,” enabling a French or German bank branch to continue operating in London for up to two years if it applies for U.K. authorization. But the EU has done little on that front, with the EC's contingency plan limited to providing temporary authorizations focusing on derivative transactions.
Many U.K.-based banks and insurance companies fortunately have EU offices and the proper licenses, Livingston said, and many more are making those arrangements to avoid disruptions to customers.
Other industries face bigger challenges. The EC's contingency plan provides U.K.-controlled airlines with 12-month authorizations to fly across the EU and make stops. However, it restricts cabotage – the transportation of goods or persons between two places in a country. So depending on the final EU legislation, U.K.-controlled airlines may no longer be able to drop off passengers or cargo in an EU airport, pick up more to fill the plane, and travel to another EU destination.
交通樞紐受阻
Airlines are working to minimize disruptions, Livingston said, noting that London's Heathrow Airport is routinely ranked as the busiest airport in Europe, with significant traffic into the EU.
Road haulage and border controls are also likely to suffer from a no-deal.
Livingston noted that the EU's contingency plan would effectively permit a limited amount of road haulage by U.K. carriers into the EU for a period of nine months, but it also restricts cabotage for trucks.
Vehicles will need international permits from the European Conference of Ministers of Transport (ECMT) to replace U.K.-issued EU permits. These have to be applied for in the preceding calendar year, so it is now too late to get one for 2019, Livingston said, and the EU proposal appears to address only the gap before 2020 permits could come into force.
In industries such as trucking, where many businesses are not large and may have limited resources, a no-deal is more likely to cause disruption, Livingston said. She added that the U.K. had announced it intended to permit road haulage with comparatively few restrictions on cabotage, provided the EU reciprocates.
公司供應(yīng)鏈可能中斷
The EC's limited solutions in areas such as transport are ultimately likely to affect large companies as well, notably auto makers and others with just-in-time manufacturing processes, and retailers relying on just-in-time supply chains.
More commercially damaging, Livingston added, would be the high rates of customs tariffson some agricultural products – upwards of 50% for sheep meat, for example.
口岸查驗(yàn)難題
In fact, ports may be another point of disruption. French ports have traditionally been ports of entry for U.K.-EU trade, but not inspection points for agricultural products coming from outside the EU.
In addition, Livingston said, duties must be paid on automobile parts and other supplies, whichever direction they are moving in. The U.K. has set up a “trusted supplier” scheme in which paperwork is handled off-site and doesn't hold up traffic.
Even if U.K. imports run smoothly, delays to exports at some continental ports could result in significant delays for returning trucks, disrupting supply chains. Simple checks that add 15 minutes to truck or container stays in port can have knock-on effects that cause a backlog.
歐盟型式批準(zhǔn)要求
If there is no deal, EU type approvals issued by the U.K. for typically more sophisticated goods such as automobiles, medicines and medical devices – indicating they meet certain EU standards – will not be accepted after March 29.
She added that multinational corporations may already have most of the necessary type approvals for their business in the EU, or have taken steps to get them. Small and mid-size businesses with fewer resources, however, may have been counting on a transition period to complete the task. Given that they are vital links in larger companies' supply chains, the challenges they face will likely ripple through the U.K. and EU economies.
“One would anticipate there to be a whole lot of unexpected problems if we crash out of the EU at the end of March,” Livingston said. Problems that “with the best will in the world people haven't been able to address.”
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