FX Global Code Published

On May 25, 2017, central banks, regulatory bodies, market participants, and industry working groups from a range of jurisdictions released the FX Global Code (the “Code”).

The Code is a common set of principles intended to enhance the integrity and effective functioning of the wholesale foreign exchange markets, certain segments of which have, to date, been largely unregulated. There are certain areas where the Code’s standards fall short of local legal and regulatory requirements or where compliance affects other regulatory obligations: signatories will need to identify and manage points of interaction (and tension) between the Code and existing and upcoming U.S. and EU legislation. In this Alert Memorandum, we summarize the key elements of the Code and provide more detail on these issues.