Andrew G Haldane: Managing global finance as a system
Text of the Maxwell Fry Annual Global Finance Lecture, given by Mr Andrew G Haldane,
Executive Director and Chief Economist of the Bank of England, at Birmingham University,
Birmingham, 29 October 2014.
* * *
Accompanying charts can be found at the end of the speech.
The views are not necessarily those of the Bank of England or the Monetary Policy Committee.
I would like to thank Ambrogio Cesa-Bianchi, Edd Denbee, Jeremy Franklin, Carsten Jung, Matt Roberts-Sklar,
Stephanie Quiet and Benedict Roth for assistance in preparing the text. I would also like to thank to Rob Elder,
Jeremy Harrison, Kristin Forbes, James Smith and Stacy Williams (HSBC FX Quantitative Strategy Team) for
insights and comments.
It is a great honour to be giving this year's Maxwell Fry Global Finance Lecture. Max was a
tremendous colleague, both during his time here at Birmingham University and as Director of
the Centre for Central Banking Studies at the Bank of England.
Max also had a rare gift. Through his exceptionally rich academic and public policy career,
he was able to integrate the insights from disciplines which all too rarely communicated -
monetary theory and central bank practice, advanced and emerging market experience,
financial markets dynamics and mainstream macro-economics.
The global financial crisis could not have provided a clearer demonstration of the benefits of
combining these insights. Without them, it would have been impossible to make sense of the
chaotic dynamics of global economies and financial systems at the time. In other words,
nothing could have provided a better case study of the importance of Max's work than the
crisis.
And it is lessons from the global financial crisis with which I want to begin. These are of
course many and varied. But among the most important is also perhaps the simplest: to
safeguard against systemic risk, the financial system needs to be managed as a system
(Haldane (2009)). As put, this statement seems rather obvious, perhaps even tautological.
Yet, pre-crisis, it was far from obvious. The orthodoxy then was that safeguarding individual
financial firms was a necessary and sufficient condition for system-wide stability. This was
the financial stability equivalent of the English aphorism: "look after the pennies and the
pounds will look after themselves". And so it appeared during the long pre-crisis period of
stable growth and stable banks - the "Great Moderation" (Bernanke (2004)).
The crisis has rewritten that orthodoxy. It revealed that the safety of individual banks was
neither a necessary nor sufficient condition for systemic stability. Not necessary because, in
any well-functioning system, individual banks can and should fail. Not sufficient because, in
an integrated web, the chain is only as strong as its weakest link.
In focussing on individual banks, policymakers had been, to coin another English aphorism,
"penny-wise but pound-foolish". That is why Great Moderation gave way to Great Recession
(Gai and Kapadia (2010)). That is why systemic risk entered the public lexicon. And that is
why financial regulation has, in the period since, been fundamentally re-oriented towards the
monitoring and management of systemic risk.
Interestingly, that lesson would have come as no surprise to anyone familiar with dynamic,
integrated networks outside of the world of finance. Assessing the stability of almost any
network known to man - whether natural, physical, social or economic - relies upon a
system-wide assessment. And protection mechanisms for this system need to be calibrated
to system-wide characteristics (Goldin and Mariathasan (2014)). Financial webs are no
exception. The history of financial crises suggests they may be closer to the rule.
This new orthodoxy has framed the post-crisis regulatory reform agenda. It is why so-called
macro-prudential policy has risen in prominence. It is why the world's most inter-connected
banks will in future be required to run with extra capital and liquidity. It is why OTC
derivatives will in future be centrally traded and cleared. And it is why resolution of the
world's largest, cross-border banks has become such a priority. For the global banking
system we now have a blueprint, an emerging new set of international rules of the road.
Yet if instead of banks we consider the financial fortunes of countries; if instead of inter-bank
exposures we consider cross-border flows of capital; and if instead of international banking
regulation we consider the international monetary system, it is far from clear that lessons
have been learned, much less that the international rules of that road have been reformed.
Arguably, the rules of the road for this system have failed to keep pace with the growing
scale and complexity of global financial flows. It is for this reason that some have called the
international monetary system a "non-system" or "anti-system" (Truman (2012) and De
Larosiere (2014)) - a system whose shape and scale has outgrown its architecture.
I want to discuss these developments and their public policy implications. I first discuss the
historical evolution of the international monetary network, including the remarkable recent
surge in financial globalisation. I then discuss why financial globalisation can be
doubleedged from a stability perspective. Finally, I consider steps to strengthen the international
architecture, to better manage global finance as a system.
The historical evolution in global finance
It is fascinating to track how global financial integration has evolved over the past century.
One way of gauging that is by looking at measured stocks of external asset and liabilities -
the cumulative consequences of past cross-border capital flows (and valuation changes).
Charts 1 and 2 plot world gross external assets, measured relative to world GDP, over the
past 140 years. As a comparison, world trade relative to world GDP is also shown.
Global integration of trade and finance has followed roughly similar patterns. Both rose prior
to World War I during the heyday of the classical Gold Standard, when trade and capital
liberalisation were last at their peak. Both then fell during the interwar years, as national
protectionism led to trade and financial barriers being erected. Then, from around 1960
onwards, trade and finance once more began to rise due to the lifting of restrictions on
crossborder trade and capital flows (Broadbent (2014)).
Despite this close historical correlation, the undulations in global finance are far greater than
those in world trade. In 1960, global finance was around one third of its value in 1914,
measured relative to world GDP. By 2010, it had risen to three times its value in 1914. Put
differently, in 1980 global trade and global finance were on a broadly equal footing, at around
a quarter of world GDP. By 2010, global finance was nine times global trade. At the same
time world trade has flat-lined, global finance has come of age.
Today, cross-border stocks of capital are almost certainly larger than at any time in human
history. We have hit a new high-water mark. The same is probably true of cross-border flows
of goods and services and is most certainly true of cross-border flows of information
(Haldane (2013)). We are accustomed to talking of the information technology revolution. Yet
the revolution in global finance has in some respects been every bit as striking.
While these trends tell us something about relative patterns of global interconnection, they
leave unanswered the question of whether global finance is a truly integrated network. To
gauge that, consider an alternative measure of global capital market integration - the
correlation between national saving and investment rates. From Feldstein and Horioka
(1980), we know that this correlation provides a proxy for capital market integration.
For example, a savings/investment correlation of one indicates a closed capital account: all
domestic investment needs to be fully financed from domestic saving. At a global level, this
would signify something close to global financial autarky. By contrast, a correlation of zero
implies that domestic investment can be fully financed on global capital markets. This would
signal something close to perfect capital market integration. So saving/investment
correlations of zero and one define the outer limits of global capital market integration.
Chart 3 plots this correlation coefficient over the same 140-year period shown in Chart 1.
Broadly-speaking, the two series track one another fairly closely. But Chart 3 now allows us
to say things about the absolute degree of capital market integration. And what a
rollercoaster ride it has been. During the first period, from around 1880 up until the Great
Depression, global financial integration sat roughly mid-way between its outer limits.
Integration was high-ish, but far from perfect.
For around a fifty year period, from the 1930s through to the 1980s, global finance then went
into hibernation. The Feldstein/Horioka coefficient skirted one for large parts of this period.
The global financial system operated as anything but a system. Indeed, it was this which
prompted Feldstein and Horioka in the early 1980s to present the "puzzle" of still-low levels
of capital market integration.
Yet at pretty much precisely the point this puzzle was being identified, it began to disappear.
Correlations quickly moved from close to unity in the early 1980s to close to zero by the start
of the 21st century. This was an astonishingly rapid evolution from a world close to financial
autarky to one close to financial nirvana. In the light of the crisis, measured levels of global
capital market integration have fallen somewhat. But they remain at higher levels than at any
point in history.
Overall, then, the picture is clear. For much of the 20th century, global finance was more
patchwork than network. But the past thirty years have seen that picture change
spectacularly. Today, global finance is a well-connected network, a tightly-woven and tangled
web, a genuine system.
The double-edged nature of financial integration
So what are the implications of this increase in global financial integration? There have been
large numbers of studies exploring the growth and welfare implications of these trends, using
cross-country and time-series evidence (Rey (2013)). This evidence paints, at best, a mixed
picture. While capital integration ought to enhance international risk-sharing, there is
surprisingly little evidence of this having conferred macro-economic benefits - and some of it
having imposed costs.
For some economists, this is a perplexing and contentious conclusion. It is made all the more
so by the fact that the evidence on global trade integration points overwhelmingly towards
positive effects (Kose et al (2009) and Berg and Krueger (2003)). Yet, outside of economics
and finance, this conclusion would be far less perplexing and contentious.
For many other disciplines, it is well-known that the increased integration of a network can be
double-edged from a stability perspective (Watts (2002), Haldane and May (2011)): whether
it is physical networks, like utility grids; or natural networks, like eco-systems; or social
networks, like the world wide web. The logic is straightforward.
Within limits, connectivity acts as a shock-absorber. Links in the system act as a mutual
insurance device, helping distribute and disperse risk. These systems are then "robust" to
shocks. But when shocks are sufficiently large, connectivity may instead serve as a
shocktransmitter. Risk-sharing becomes risk-spreading. Links in the system act as a mutual
incendiary device, amplifying risk. These systems are then also "fragile".
So connected systems tend simultaneously to be both stable and unstable, calm and
turbulent, robust-yet-fragile (Acemoglu et al (2013), Gai and Kapadia (2010)). In other words,
integration can be double-edged. It generates a world with instances of more frequent and/or
larger dislocations. In short, what is true of natural, physical and social systems is also true of
global economic and financial systems.
To illustrate that, consider Chart 4. This shows the results of a simulation of a hypothetical
financial network of firms. These have differing levels of financial strength, measured on the
x-axis. Think of this as a country's level of official reserves or a bank's level of liquid assets.
On the z-axis is a measure of network interconnectivity - the scale of cross-border assets or
interbank exposures. Finally, on the y-axis is a measure of systemic risk - the incidence of
default across the network, whether of countries or banks.
As the network becomes better integrated, for a given degree of financial strength, systemic
risk remains low. We operate in a zone of systemic stability. That is because the network is
operating as a shock-absorber, a network insurance device scattering risk to the four
corners. So it was pre-crisis.
But for a large-enough shock to financial strength, the system fundamentally changes shape.
The network flips to a zone of systemic instability. That is because it is now operating as a
shock-transmitter, a network incendiary device - and the greater the degree of integration,
the sharper this knife-edge. So it was during the crisis.
This is the robust-yet-fragile property of connected webs. The global financial crisis provided
no better example. The flat earth that was the Great Moderation gave way to the fragile
planet that was the Great Recession. Risk-sharing gave way to risk spreading, risk
distribution to risk contagion.
This was by no means an isolated incident. Chart 5 plots a measure of global capital market
integration (external assets/GDP) against a measure of the incidence of crises - all crises
and banking crises (Reinhart and Rogoff (2011)). Integration appears to have been
associated with an increase in the incidence of crisis over the past couple of decades,
perhaps especially banking crises.
It is not just the incidence, but also the prospective size of crises and their spill-over
consequences that has increased. Chart 6 provides one perspective on that. It looks at the
scale of IMF programmes over time, normalised by the borrowing country's quota. Two
features are striking: first, the increased incidence of programmes; but second, more
dramatically, their increased scale.
Academic evidence has long pointed towards important spillover effects from national or
international disturbances (Obstfeld and Rogoff (1995), Forbes and Warnock (2012) and
Fratzscher (2012)). But recent evidence points towards more potent contagion channels. For
example, Rey (2013) finds evidence that a common global risk factor drives asset prices and
cross-border capital flows, for both advanced and emerging economies.
It is worth putting under the microscope these shifting patterns in global financial market
correlations, especially over the most recent period. Charts 7-9 plot correlations between
long-term bond yields, equity prices and investment grade corporate bond spreads
respectively in the US, UK and the euro-area over the past few decades. Two features stand
out.
First, there has been a steady rise in the degree of co-movement in asset prices over time.
Take government bond yields over the past 50 years. Over the first quarter century, from
1960 through to the mid-1980s, average pairwise correlations between bond yields were
around 0.1. Over the subsequent quarter-century, these correlations have risen steadily,
averaging 0.7 over the latter part of the sample (Chart 7).
Second, and more striking still, is the level reached by these correlation coefficients towards
the end of the sample. Whether it is safe government assets or risky corporate bonds and
equities, correlations typically lie in the range 0.7 to 0.9. Other things equal, a common global
factor potentially accounts for perhaps 70-90% of the movements in advanced country asset
prices.
These correlation patterns are stronger, and even more striking, when we look at their
evolution over time. As one example of that, Charts 10 and 11 plot "heatmaps" of the
strength of a common factor in the variation of spot and forward rates respectively for
government bonds at different maturities in the UK, US and Germany over the period since
1995.
In general, they show the same pattern of high and rising correlations over time. But these
correlations also show distinctive flare-ups, associated with spasms in global financial
markets such as the global financial crisis and last year's 'taper tantrum'. By the end of the
sample almost the whole of the yield curve, bar the very short end, is moving synchronously
across countries. To a first approximation, global yield curves appear these days to be
dancing to a common tune.
All of this evidence points in one direction: the global monetary system operates in a similar
fashion to all other tightly-knit networks - it is robust yet at the same time fragile. It is driven
by potent - increasingly potent - spillover effects and common global factors. In short, global
finance can only be understood and managed as a system.
Characteristics of the global financial network
The next obvious question is what mechanisms are in place to underpin the resilience of this
tightly-woven web? Let me highlight some key characteristics of the global financial network
which are useful in assessing its robustness. And let's start with the good news.
One positive trend in the international flow of funds is their changing composition. Table 1
breaks down these flows of funds into their foreign direct investment (FDI), portfolio and debt
components, for advanced and emerging markets, over the periods 1980-1994 and
1995-2012. Two features stand out.
First, the declining share of debt-based finance and second, as the counterpart to this, the
rising share of portfolio and in particular FDI investment. For example, since 1995 the
dominant source of emerging market capital has switched dramatically from debt-based
finance towards FDI. Equity and FDI together now account for two-thirds of emerging market
financing.
That is significant from a stability perspective. Empirical evidence strongly suggests that FDI
and, to a lesser extent, equity is a far more stable source of external financing than bank
debt (Kose et al (2009)).1 That is in part because of its longer duration and in part because of
its superior risk-sharing properties. For at least some emerging markets, their national
balance sheets appear to be moving to a more robust footing.
A second positive development comes from looking at countries' degree of self-insurance, in
particular their stock of foreign exchange reserves. As Chart 12 shows, these have grown
dramatically since the second world war and especially since the Asian crisis, both in money
terms and relative to world GDP. Reserves have risen from $1.5 trillion in 1995 to over
$11 trillion by end-2013, or from around 5% of world GDP to around 15% today.
Third, this has been accompanied by some augmentation of multilateral official sector
facilities for helping handle external financing shocks. For example, since 1980 IMF quota
resources have risen from just under $80 billion to around $370 billion, or from 0.7% to just
less than 2% of world GDP (Chart 13). The most significant augmentation in resources came
from the New Arrangements to Borrow (NAB) in 2009, which were agreed to increase
temporarily the resources available to the IMF at the height of the financial crisis.
Fourth, alongside these multilateral facilities, the past few years have seen rapid growth in
regional and bilateral financing facilities (Chart 14). Regionally, we now have a number of
financing arrangements, including the Chiang Mai initiative in Asia (established in 2000), the
European Stability Mechanism (established in 2012), the Latin American Reserve Fund
(established in 1991), the Arab Monetary Fund (established in 1976) and, most recently, the
BRICS development bank (established in 2014)). Regional facilities now total around
$1.3 trillion.
In addition, during the course of the crisis, bilateral foreign currency swap lines were agreed
between around 14 central banks, in both advanced and emerging market countries.
Although these swap lines were temporary, in October 2013 they were replaced by a set of
permanent, and potentially unlimited, swap lines among a group of advanced economy
central banks: the US, Canada, the UK, the euro-area, Switzerland and Japan.
These four developments, in combination, are likely to have increased significantly the
potential pool of liquidity insurance available to the global financial system in dealing with
external financing shocks. The question is whether this degree of insurance has kept pace
with the accompanying rising tide of global capital market integration.
One metric for that is found by scaling countries' foreign exchange reserves by a measure of
financial globalisation - for example, total external assets (Chart 15). Despite the rapid rise in
reserves, its ratio to external asset stocks has actually fallen since 1980, from 10% to around
8%.
Second, official reserves have risen unevenly across countries: the degree of concentration
in reserves has increased threefold since 2000. Moreover, those countries most at risk from
capital flight are not necessarily those with the highest reserves. Scaling countries' reserves
by measures of their external short-term indebtedness suggests a highly-uneven pattern
(Chart 16), with a number of countries holding less than would be needed to meet a year's
worth of capital outflows.
Third, this pattern is broadly mirrored when moving from measures of self-insurance, such as
reserves, to official financing measures. Chart 17 scales IMF resources by external assets.
Since the 1980s, this measure has roughly halved from 3% to 1.5%. And fourth, even once
we augment multilateral financing with measures of regional official financing, total official
resources relative to external assets are still shy of their levels in 1980.
Taken in combination, this paints a picture of an international monetary system whose
underlying topology has fundamentally changed shape and scale - much larger, much more
connected. But it is also a system whose architecture may have failed to keep pace with
those changes. Therein lies a key potential fault-line.
Strengthening the system
This naturally begs the question - what might be done to close this fault-line, to improve the
resilience of the international monetary system? One response would be to retreat from
financial globalisation by re-imposing barriers to capital movement, unravelling the
tightlywoven knitting of the global financial web. We have seen this movie before. It opened in the
aftermath of the Great Depression and ended in disaster.
There should be better ways of making financial globalisation work, while guarding against its
darkest consequences - to achieve robustness without fragility. But this may require new
tools and approaches, operating system-wide. It may even require a new architecture, strong
enough to withstand the new scale and scope of systemic risks.
Let me discuss four areas where progress could realistically be made in developing this new
architecture: financial surveillance; debt structures; macro-prudential policies; and multilateral
financing. Each would be an important new brick in the wall.
(a) Improvements to global financial surveillance
Forewarned is forearmed. Understanding the dynamics of the international monetary system,
its tipping points and edges, is a pre-requisite for effective management. Some progress has
been made on this front. For example, the IMF's Global Financial Stability Report has, since
2002, sought to plot the evolving contours of global finance. And the publication by the IMF
of "Spillover Reports", since 2011, is a further step in the right direction.
Nonetheless, these steps only take us so far. The centrepiece of the IMF's surveillance
efforts remain the country-specific Article IV consultations. Whether that country-specific
focus, enshrined in the IMF's 1944 Articles, can be justified in today's highly integrated global
financial network is a more open question. This year's IMF Triennial Surveillance Review
may be an opportunity to tilt the balance further towards multilateral surveillance.
What more might be feasible? I have a dream. It is futuristic, but realistic. It involves a Star
Trek chair and a bank of monitors. It would involve tracking the global flow of funds in close
to real time (from a Star Trek chair using a bank of monitors), in much the same way as
happens with global weather systems and global internet traffic (Haldane (2011)). Its centre
piece would be a global map of financial flows, charting spill-overs and correlations.
Such a global financial surveillance system could serve a number of policy ends. It would
allow policymakers to monitor the evolution of the financial system in real time, as it
expanded, contracted and changed shape. It would also allow them to simulate and
stresstest this system to help detect impending financial cliff-edges. The IMF would be the natural
guardian of this global-financial-map-cum-stress-testing-machine.
To give this concept some (literal and metaphorical) colour, Chart 18 shows a bank of
heatmaps of correlations across a wide range of assets (safe and risky) and a large set of
countries (advanced and emerging). There are shown at three dates - a pre-crisis period of
calm, the Lehmans Brothers crisis of 2008 and at present. These correlations are grouped in
two ways, by asset class and by country.
The correlation matrix broadly matches the patterns from the earlier heatmaps.
Temperatures appear to be rising over time, with flare-ups at times of crisis. With this map
now encompassing a wider range of assets and countries, the strength of these correlations
underscores the genuinely global nature of today's international financial system.
But there is a second, more striking pattern which emerges when these correlations are
grouped by asset class and by country. Correlations are far higher by asset class than by
country. In other words, there is greater co-movement among similar asset types across
countries than among different asset types within countries. A portfolio-level cut is more
revealing about the underlying dynamics of global finance than a country-specific cut.
How to make sense of these patterns? One explanation may lie in the behaviour of global
asset managers. Financial markets are increasingly driven by their behaviour (IMF (2014)).
For asset managers, the key determinants of their portfolio choice may be the risk
characteristics of different asset classes, rather than their country characteristics. Certainly,
that is consistent with the correlation patterns.
Either way, these patterns serve to underline the importance of multilateral and
spilloverbased analysis, as distinct from country-specific (Article IV) surveillance, when assessing
risks to both global and national financial systems. They also carry potentially important
implications for how these dynamics might most effectively be managed from a
macroprudential perspective (discussed below).
(b) Improvements to country debt structures (and restructures)
Debt flows are known to be a potent source of instability within the international monetary
system. The instabilities they generate are exacerbated by frictions in the design of debt
contracts. One such friction is that debt is an inherently pro-cyclical instrument. For example,
a negative shock to a country's income prospects will tend to raise debt sustainability
concerns and hence borrowing costs, thereby worsening sustainability.
Another friction is that, once internationally-held debt becomes unsustainable, restructuring it
is usually a messy process because of the lack of an internationally-agreed legal framework.
In part for that reason, countries have tended to delay tackling unsustainable debt. But if debt
is truly unsustainable, delay tends to further worsen debt dynamics, ultimately increasing
costs for both debtors and creditors (Krugman (1988)).
These contractual frictions can make debt a fickle friend. They will tend to aggravate debt
sustainability and debtor prevarication problems, thereby encouraging investors to withdraw
credit at the first sign of trouble - so-called "sudden stops" (Calvo (1998)). These frictions are
well-illustrated by historical sovereign debt restructuring experience, most recently in
emerging market economies such as Argentina.
Yet it is widely accepted that there are straightforward contractual solutions to these debt
problems. One is to issue debt instruments whose contractual features reduce pro-cyclicality,
such as GDP-linked bonds. Their repayment profile adjusts with a country's ability to pay,
thereby acting counter-cyclically and quasi-automatically to defuse repayment risk (Shiller
(1993 and 2003), Barr et al (2014)).
The impact of such instruments on debt dynamics could be significant. A recent Bank of
England study considered the debt-to-income ratios of the G7 countries, given shocks to
growth and real interest rates, comparing conventional and GDP-linked debt. The latter cut
the variability of G7 debt-to-income ratios in half. Yet despite their attraction, no more than a
handful of countries internationally have so far issued GDP-linked debt instruments.
Contingent convertible ("CoCo") bonds are a second, potentially useful, debt instrument.
These have been popular recently among banks. For countries, they could be designed with
a duration which is automatically extended if a country breaches certain pre-set stress
conditions - for example, if it is the subject of an IMF lending programme (Brooke et al
(2012)). This would then deliver some automatic alleviation of short-term liquidity pressures.
So far, no country has issued such instruments.
There has been somewhat greater progress towards the inclusion of contractual clauses
which assist in the restructuring of sovereign debts once these become unsustainable. In
particular, following the Asian crisis there was a push by the international community to
include Collective Action Clauses (CACs) in international bond contracts.
Yet as recent Argentine experience illustrates, this has not closed the book on sovereign
debt restructuring problems. Existing CACs tend only to cover one particular class of bonds.
This gives rise to a potential aggregation problem if other classes of bond vote against - or
hold-out from - a restructuring agreement.
"Aggregation" CACs include the option for bonds to be restructured on the basis of a single
vote across all affected bonds. A recent IMF paper proposed that these clauses be included
in foreign law bonds, a proposal which appears to have the support of the international
community (IMF (2014)). Kazakhstan recently incorporated these clauses into its bond
programme.
The international community may in future need to provide stronger incentives to countries to
improve debt structures, be it through GDP-linked bonds, CoCos or CACs. Linking the
availability or terms of IMF financing more explicitly to debt structures might be one way of
doing so.
(c) Enhanced macro-prudential and capital flow management policies
Significant progress has been made over the past decade in the design and implementation
of macro-prudential regimes and capital flow management policies. The shift in the prevailing
orthodoxy, analytically and operationally, has been remarkable.
A decade ago, policies to manage actively inflows and outflows of capital were frowned upon
by the IMF and the international community. Yet today these measures have been largely
accepted as part of the toolkit for protecting countries from boom and bust cycles in capital
flows (IMF (2012)). Perhaps most significantly of all, more than 40 countries have already
deployed these measures since 2009.
A great many analytical and operational issues remain open. What are appropriate states of
the world for introducing and releasing capital flow management measures - a first or last
resort? Which policy measures are likely to be most effective - outflow versus inflow, price
versus quantity controls? And how do these policies operate alongside other arms of policy -
monetary, macro-prudential and micro-prudential?
At present, we have neither the theory nor the experience to answer these questions
definitively. But case law is rapidly emerging, including on their potentially adverse
crossborder spillover consequences (Forbes et al (2013) and Magud et al (2011)). Looking to the
fu