Brexit scenario by Ebury. Andras Mecser

1. +44 (0) 20 3872 6670 | info@ebury.com |
ebury.com
Ebury Belgium Fintech Summit 2017
Societal Impact of Fintech

2. 01 Ebury
02 Potential implication of Brexit on Ebury's business model
03 Belgium as the first choice for Brexit plan
Agenda2
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3. Ebury thrives to be the GTA for SMEs3
Working with
24,000+ businesses
& organisations
13 Countries, 15
Offices. London,
Manchester, Madrid,
Málaga, Lisbon,
Amsterdam, Brussels,
Zurich, Paris,
Dusseldorf, Athens,
Warsaw, Milan, Toronto
and Dubai
Traded $8.2bn in foreign
exchange in the last 12
months
Backed by well-known
and respected technology
investors
Direct “SUPE” SWIFT
member and SWIFT gpi
member.
Over 20,000 transactions
per month. Capability
in over 110 currencies.
Delivered to 214
jurisdictions.
Ebury is one of Europe’s fastest-growing fintech companies,
providing FX liquidity, volatility risk management, international payments
and trade finance to SME’s.
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4. We are a payment institution, not a bank
• Ebury Partners UK Limited is an Electronic Money Institution regulated
by the FCA in the UK and Passported across the EEA. Reg. No.
900797
• Ebury Partners Belgium BV is registered as a Payment Institution with
the NBB in Belgium.
• Ebury Partners Canada Limited is regulated by FINTRAC for
Money Exchange Dealing and Money Transferring. Reg No.
M17949017
• All our products (incl. FX hedging) are payment solutions not financial
instruments.
• This limits our risk when offering these products to our clients and make
us more nimble.
We facilitate B2B cross-border transactions, not B2C or
in-country transactions
• Ebury’s core capabilities are built to support B2B transactions and to
offer global transaction services to SMEs
• FX hedging capabilities are our main USP and therefore we are not
focusing on B2C transactions with no FX component (e.g., in-country
transactions)
1. Cross-border payments
• Make cross-border payments simple and fast in 110+ currencies,
including illiquid EM currencies
2. FX hedging with liquidity
• Great breadth of FX hedging solutions and offer hedging capabilities in
65 currencies
• Minimise cash tied up in forward contracts hedging currency risk
3. Cash management and bank account provision
• Provide designated currency accounts in 68 currencies for international
cash management purposes
• Collect funds from buyers in different countries
4. Direct Lending – Import Finance
• Working capital financing associated with the import cycle
4 Ebury business model and products
PRODUCTSBUSINESS
MODEL
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5. Ebury`s journey so far5
2014
Launch of Trade
Finance in 2014 and
opening Amsterdam
office
+44 (0) 20 3872 6670 | info@ebury.com | ebury.com
2009
Founded
2011
Madrid office opened
2011
First trade and
expanded to Málaga
2016
Over 400 employees in
2016 and expansion to
Zurich, Paris and
Athens
2015
Expanded to Warsaw
in June 2015 and Raised
$83m in November 2015
2017
SWIFT gpi members in 2017.
Opened offices in Toronto, Dubai,
Lisbon, Milan, Brussels, Manchester
& Dusseldorf. Over 550 employees.

6. Brexit implications - business model @ risk
1 Regulation
• Risk of potentially losing Ebury’s passporting rights
• Uncertainty of access to the single market resources based on the changing bilateral agreements
between UK and the EU member states
• Potential negative impact on the operational stability through regulatory changes in the UK after EU
separation
2 Risk
• Funding needs due to sharp market move
• Credit worthiness of UK importers
• Credit worthiness of underlying clients
6

7. Brexit scenario planning - Project Eurogeddon7
Ebury needed to define a sustainable regulatory structure that enables the group to offer its services
across Europe regardless the outcome of Brexit negotiations ensuring continuous service for our clients
Three different scenarios as a Brexit outcome:
Scenario 1)
UK still has access to the single market --> no change in license
requirements
Ebury would be able to operate under its current cross-border business
model (UK FCA regulated firm, passporting its license to Europe)
Scenario 2)
UK loses its access to the single market, rest of EEA intact --> one
API license in an EU jurisdiction passported across
Under this scenario, Ebury would service the UK client base under the
FCA license and service the European client base under an EU API
license (current UK model replicated out of a European country)
Scenario 3)
UK loses its access to the single market, other European countries
leave the EEA --> local regulation across European hubs and the UK
Ebury would require to obtain API licenses in all the jurisdictions where it
offers services
Ebury UK
(FCA license)
Ebury EU
(EU license)
Ebury UK
(FCA license)
Ebury Belgium
(NBB license)
Ebury Spain
(BoS license)
Ebury Germany
(BoG license) Ebury Italy
(BoI license)
Scenario 2
Scenario 3

8. Key for Ebury was the minimal disruption to its current business
model..
Selection framework
Considerations on regulations • Proactive regulatory attitude
• Regulatory experience
• Process of getting regulated (complexity and time)
• Flexibility in onshoring /offshoring functions
• Legal enforcement framework
Ongoing administrative requirements • Corporate Governance and Employment Law
Considerations relating to operational costs • Tax considerations
• Reporting requirements
Other considerations • Regulatory stability and European embeddedness
• Accessibility and language consideration
8

9. Belgium and Ireland were short listed
Country assessment1:
Proactive regulation
Regulatory experience
Process of getting regulated (complexity and time)
Flexibility in onshoring /offshoring functions
Legal enforcement framework
Corporate Governance and Employment Law
Tax considerations and reporting requirements
10
1 Ebury`s own analysis

10. 11
Belgium was the preferred option mainly due to lower
running cost and more proactive regulation
+44 (0) 20 3872 6670 | info@ebury.com | ebury.com
Regulator
Process
Requirements
Lobbying
Legal enforcement
framework and
employment law
Other considerations
Language
• Two supervisors
• NBB – licenced entities, single point of contact
• FSMA – financial consumer protection
• Forward thinking regulator with dedicated Fintech team
• No enforcement against PIs to date with maximum fine lower than Ireland
• Experienced entity (14 APIs and 5 EMIs already registered)
• Faster licensing process assessment up to 3 months
• NBB requires initial and pre-application meetings
• Company incorporation process takes 1-2 months
• Local corporate tax at 34%
• EMIR reporting required
• Local office required
• 2-3 directors/ key employees on the ground (part-time)
• 24/7 presence not required for the above
• No local supervision
• Firms could lobby on legislation derived from network between EU
institutions and Belgian firms
• Unfair dismissal after 6 months
• Slower contractual enforcement (6-12 months)
• Following English law possible (might change w/Brexit)
• EU capital
• Increased terror threat
• French/Dutch
• Direct communication available in English

11. 100 Victoria Street, London SW1E 5JL | +44 (0) 20 3872 6670 |
info@ebury.com
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© Copyright 2009-2017
Ebury Partners UK Limited. Company registered in England and Wales (registered no. 7088713). Registered office: 3rd floor, 100 Victoria Street, Cardinal Place, London, SW1E 5JL. Ebury Partners UK Limited is authorised and regulated
by the Financial Conduct Authority as an Authorised Electronic Money Institution (Financial Services Register No. 900797).