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Strengthening Principles & Code of Conduct Standards in FX Markets

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Who will the FX Global Code apply to?

The Global Code of Conduct for the Foreign Exchange Market is written to encompass all those that participate within the FX Market.

“The Global Code will evolve, as required, over time as the FX Market evolves”

Phase 1: Material for Global FX Code May 2016, FXWG

Published June 2016

FX Market Participants

With the Foreign Exchange Market being made up of such a diverse range of Market Participants, the FXWG are aiming to write the FX Global Code to take into account the different types of engagement within the Market and the variety of foreign exchange products that are available.

The Global Code is therefore expected to apply to all  Market Participants that engage in the Foreign Exchange Market.

This will include both buy-side and sell-side entities, Trading Venue operators, non-bank liquidity providers and other service providers such as those that offer brokerage, execution and settlement services.

However, the FXWG seem to understand that “there can be no universal ‘one-size fits all’ approach”, however they see the Global Code as being intended to establish a common set of guidelines for responsible participation within the FX Market.

Market Participants will be both persons and organisations of any legal form that either:

  1. Operates a system, facility, platform or organisation that enables participants within the FX Market to execute any  of the the types of transactions detailed in 2 below:
  2. Is active in the Foreign Exchange Market as a regular part of its business and is engaged in:


  1. Provides Foreign Exchange benchmark execution services; and
  2. Is not considered a Retail Market Participant in the relevant jurisdiction(s).

*The Global Code is still to be finalised and thus the relevance and applicability to FX futures is still be evaluated.

Example of Affected FX Market Participants

According to the FXWG, thus the types of entities that would generally be expected to participate in foreign exchange activities - thus be FX Market Participants - might be as follows:

Persons not expected to be affected:

However, the FXWG, (according to their May16 initial Global Code publication) do not anticipate that the following persons would be expected to engage as FX Market Participants, and thus not be affected:

Who will the FX Global Code affect?

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**UPDATE 2018**: The FX Global Code is now published! Read more up to date information on our page The Global FX Code: Who Does it Apply to?