ALERT MEMORANDUM The FX Global Code July 6, 2017 On May 25, 2017, central banks, regulatory bodies, If you have any questions concerning market participants, and industry working groups from this memorandum, please reach out to your regular firm contact or the a range of jurisdictions released the FX Global Code following authors (the “Code”).1 The Code is a common set of principles intended to enhance the integrity and effective LONDON functioning of the wholesale foreign exchange markets Bob Penn (“FX markets”), certain segments of which have, to +44 20 7614 2277
[email protected] date, been largely unregulated. The Code will Anna Lewis-Martinez supplement, rather than replace, the legal and +44 20 7847 6823 regulatory obligations of adherents.
[email protected] Although the Code includes principles that are akin to Christina Edward +44 20 7614 2201 many of the requirements under the new Markets in
[email protected] Financial Instruments Directive package (“MiFID II”) and U.S. Commodity Futures Trading Commission NEW YORK Colin D. Lloyd (“CFTC”) rules under the Dodd-Frank Wall Street +1 212 225 2809
[email protected] Reform and Consumer Protection Act of 2010 (“Dodd-Frank Act”), in several respects the Code Brian Morris +1 212 225 2795 goes beyond those requirements. As such, for many
[email protected] market participants, adherence to the Code will require Truc Doan material changes to existing operating models, +1 212 225 2305 compliance procedures, client disclosures, and other
[email protected] documentation. Adherence to the Code is voluntary, but several regulators have expressed that they expect market participants to adhere, and there will be public and private sector pressure to publicize adherence.