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In brief

In July of 2017, Andrew Bailey, the chief executive of the UK Financial Conduct Authority (FCA), announced in a speech that after 2021 the FCA would no longer use its power to compel panel banks to submit rate information used to determine the London Interbank Offered Rate (LIBOR). Mr. Bailey encouraged the market to develop robust alternative reference rates to replace LIBOR.

LIBOR has long been the dominant rate for determining interest payments on adjustable-rate financial products and, although progress is being made, LIBOR transition remains a fundamental issue confronting financial markets. Understanding and planning for the impact on your business is key to a smooth transition. Baker McKenzie is pleased to provide expert guidance on this issue below. Please do get in touch if you’d like to learn more.

Featured Report: LIBOR’s Long Goodbye

To date, transition has been slower than regulators would like, and considerable uncertainty still exists (and may well remain for some time). Time is growing shorter until the end of 2021, yet a large number of legacy contracts still refer to LIBOR, and new LIBOR contracts are still being written, in each case that mature after 2021. The official sector of regulators and central banks continues to stress the need to develop robust alternative reference rates and robust contractual fallbacks in the event that LIBOR were to cease or become unrepresentative of underlying financial reality, and to transition to such alternative rates. Despite the uncertainty that exists, the FCA has reiterated firmly that the end-2021 deadline remains in effect.

This report assesses the state of readiness for transition from LIBOR (and other interbank offered rates (IBORs)) to alternative interest rates in the jurisdictions of each LIBOR currency (and select other jurisdictions) with respect to derivatives, loans, bonds and securitizations. We have also produced a matrix showing an assessment of readiness for transition by currency and product type. For a print-friendly version of this report, please click here, and for the matrix please click here.


Michael Foundethakis acted as the global chair of Baker McKenzie’s Banking & Finance Practice Group from May 2017 to July 2020. He currently heads Banking & Finance in Paris and continues to act as global head of Project and Trade & Export Finance for the firm. Mr. Foundethakis is highly recommended as a leading banking and finance lawyer by Chambers Global, Legal 500, JUVE and IFLR. Additionally, he was the exclusive winner of the ILO Client Choice Award 2011 in Banking for Germany and again winner of the same award in 2017 in Banking for France. A team led by Michael Foundethakis was awarded Banking, Finance & Restructuring Team of the Year at The African Legal Awards 2015.


Koen Vanhaerents joined Baker McKenzie in 1987 and was admitted to the Brussels’ bar in the same year. He was made partner in 1994. Koen Vanhaerents has an extensive Mergers & Acquisitions, Private Equity, Securities and Corporate Finance practice. From October 2009 to October 2014, Koen Vanhaerents was a member of the Firm’s Global Executive Committee and Chairman of the EMEA Region of the Firm. Since October 2014, he is Head of Global Capital Markets Practice Group.