Citigroup is considering moving some of its London-based equity and interest-rate derivatives traders to Frankfurt after Brexit is triggered, according to people with knowledge of the matter.

The US firm is already in discussions with the German financial regulator BaFin about getting the necessary approvals, said the people, who asked not to be identified because the talks are private. Citigroup’s plans could change depending on how the negotiations between the UK and European Union develop, one of the people said.

Citigroup’s efforts show banks are shifting from warning about moving jobs from Britain to firming up plans to do so by picking specific destinations. The US bank expects to have desks up and running across the region before the end of the expected two-year negotiation period and is in discussions with the European Central Bank and regulators in EU nations including Ireland about relocating other parts of its operations, one of the people said.

“We are evaluating our options as negotiations between the EU and UK continue,” Edwina Frawley-Gangahar, a Citigroup spokeswoman, said in an e-mailed statement. “Considerable uncertainty remains over the nature of the UK’s eventual exit from the EU, and therefore we have not taken any decisions at this point. London is, and will remain, our EMEA headquarters and a global hub for many of our businesses.”

Spokesmen for BaFin and the ECB declined to comment.

Executives from banks including Citigroup, JPMorgan and Morgan Stanley have said they will move staff from London if the UK is stripped of so-called passporting rights. The problem is particularly acute for Wall Street firms, who have a majority of their European employees in London. Eighty-seven percent of US investment banks’ EU staff are located in the UK, which is also home to 78 per cent of the region’s capital markets activity, according to New Financial, a think tank.

Officials from a host of European locales, such as Paris and Luxembourg, have been courting London-based investment banks ever since the UK voted to leave the EU on 23 June.

Germany’s financial capital has an asset in BaFin, one of the few regulators in the region with experience overseeing complicated derivatives trading businesses. That’s not the case in Dublin, often touted as a likely destination for U.S. banks given language and cultural ties. Ireland’s financial regulator has made it clear that it would not be comfortable with the nation housing derivatives operations, one of the people said.

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One of London’s historic advantages over Frankfurt has been German labour laws, which make it harder for banks to fire staff in a downturn. In a bid to make Frankfurt more attractive, the regional Hesse government is exploring ways to loosen those rules.

The head of the Frankfurt Main Finance trade body, Hubertus Vath, said last month that he expects as many as 10,000 jobs could move to Frankfurt from London over the next five years. Hesse Economy Minister Tarek Al Wazir said this week that he expected the Frankfurt region to draw several thousand jobs and noted that a Korean bank had already chosen the area over London, potentially meaning the hiring of as many as 15 people.