A new Global Code of Conduct launched by the Bank for International Settlements (BIS) sets out principles of good practice for the wholesale FX market. The Code does not impose legal or regulatory obligations on market participants nor does it substitute for regulation. The principles are designed to guide both sell- and buy-side market participants and come along with mechanisms to promote global adherence.
The Code is the result of two years’ work from a public-private sector partnership between the working group of the BIS Markets Committee and a group of leading market participants from around the world. Guy Debelle, Deputy Governor of the Reserve Bank of Australia (RBA), chair of the BIS working group, said the Code was created with the aim of ‘moving the market to a better place’.
ETOS Marketing Director Sally O’Keefe welcomes the Code, commenting: “Following the string of FX scandals in recent times and consequent lack of trust between market participants, we applaud the Code as it endeavors to promote integrity and restore confidence in the FX market. Having been involved in FX markets for close to 20 years both from a bank’s perspective and also working with the multi-bank FX trading portal 360T, I believe that this should bring trust to the FX market and can only be a good thing.
“As for our local markets in Australia and New Zealand, we are optimistic that the instrumental direction provided by Guy Debelle will ensure that our clients’ banks adhere to the Code. Mr Debelle has stated that the RBA will sign up to the Code and will require all their counterparties to do the same. He has even suggested that, from a corporate perspective, support of the Code provides an indication of the standard of behaviour at that bank — if your bank doesn’t sign up, it may be time to look for another bank.”
The Global Code has been organised around six leading principles, summarised below:
Market participants are expected to behave in an ethical and professional manner to promote the fairness and integrity of the FX Market.
Market participants are expected to have a sound and effective governance framework to provide for clear responsibility and comprehensive oversight of their FX Market activity and to promote responsible engagement in the FX Market.
Market participants are expected to exercise care when negotiating and executing transactions in order to promote a robust, fair, open, liquid, and appropriately transparent FX Market.
Market participants are expected to be clear and accurate in their communications and to protect Confidential Information to promote effective communication that supports a robust, fair, open, liquid, and appropriately transparent FX Market.
Risk Management and Compliance:
Market participants are expected to promote and maintain a robust control and compliance environment to effectively identify, manage, and report on the risks associated with their engagement in the FX Market.
Confirmation and Settlement Processes:
Market participants are expected to put in place robust, efficient, transparent, and risk-mitigating post-trade processes to promote the predictable, smooth, and timely settlement of transactions in the FX Market.
The Code will be periodically reviewed and is expected to evolve over time in a similarly collaborative manner. The new Code supplants existing codes present in the FX market and market participants will be expected to adjust their practices, where necessary, over the coming 6 to 12-months.
An annex to the Code lists each of its 55 principles including examples to illustrate the principles and the situations in which they could apply. Examples include conduct that is to be avoided and examples that illustrate conduct that the Code aims to foster and reinforce.
You can view the Global Code in full here.