What remains
The transaction still requires regulatory approval from the UK’s Prudential Regulation Authority, the Financial Conduct Authority, Lloyd’s of London, and Switzerland’s Financial Market Supervisory Authority, alongside the ongoing EU review. Of these, the PRA review is the most substantive – on a change of control of this kind, the PRA takes the lead on UK regulatory assessment, consulting with the FCA and co-ordinating with international regulators to ensure effective group-wide supervision. The EU Phase I review, by contrast, operates to a defined timetable and given the limited geographic and product overlap identified by the ACCC’s own analysis, a straightforward clearance is the more probable outcome.