O spirit of love, how quick and fresh art thou,

Yet notwithstanding thy capacity

Thou receivest as the sea: nought enters thee,

Of what validity and pitch soe’er,

But that falls into abasement and low price

even in a minute.

W. Shakespeare, Twelfth Night, Act I Scene 1

Long dismissed out of hand, the notion that a country in Europe’s southern tier of “cloudless climes and starry skies” could abandon the euro to return to its own currency became a focus of attention in October 2011 when the then-prime minister of Greece threatened to submit to a popular referendum the negotiated bailout of his beleaguered country by other members of the European Union (“EU”) and the International Monetary Fund.

The agreement in December 2011 by 26 member states of the EU to create a new treaty framework using EU institutions in unaccustomed ways to enforce structural reforms and fiscal discipline among eurozone states created a frisson of optimism that the euro would not cease to be legal currency in any member state of the eurozone. However, the refusal of Great Britain to sign the treaty and legal concerns that EU institutions are not competent to act under a treaty that has not been agreed to by all EU members dampened the sense of relief engendered by that agreement. In December 2011 the concern that one or more stressed nation-states could exit the euro resulted in the inclusion of a risk factor in a draft prospectus for the European Financial Stability Facility to the effect that the euro could break apart or even cease to be a “lawful currency” entirely.