Minutes of the London FXJSC Legal Sub-Committee Meeting - 14 September 2021

The Bank of England chairs the London Foreign Exchange Joint Standing Committee (FXJSC) Legal Sub-Committee. The FXJSC is made up of market participants, infrastructure providers and the UK financial regulators.
Published on 24 November 2021

Date: 14 September 2021

Time: 3pm – 5pm | Location: Video meeting


Item 1 – Introduction and Minutes

The minutes of the meeting of 10 June 2021 were approved.

Item 2 – Global FX Code review wrap up

Grigoria Christodoulou of the FXJSC and Global Foreign Exchange Committee (GFXC) Secretariats provided an update on the three-year review of the Global FX Code (‘Code’). The amended Code text was published in July 2021footnote [1] and incorporated changes to 11 out of the 55 principles to strengthen the Code’s guidance on anonymous trading, algorithmic trading and transaction cost analysis (TCA), disclosures and settlement risk. The GFXC also published a suite of new material to support increased transparency including disclosures cover sheets for liquidity providers and e-FX trading platforms as well as templates for TCA data provision and also due diligence. Guidance papers on Principles 11 (pre hedging) and 17 (last look) of the Code were also released. Grigoria outlined the plans for the first wave of completed cover sheets being published on public registers later in the year. The Main FXJSC Committee were due to discuss expectations around the renewal of the member Statements of Commitment to the Code at their upcoming meeting.

Item 3 – Introduction to EMTA

Leslie Jacobs from EMTA gave the group an introduction to EMTA and an overview of the of EMTA’s upcoming work. EMTA is a trade group for emerging markets trading and investment community and is focused on promoting the orderly development of fair, efficient and transparent trading markets for emerging markets instruments and to helping integrate the emerging markets into the global capital markets.

Leslie outlined EMTA’s work, including EMTA’s FX and currency derivatives templates and guidance documents. Leslie also outlined EMTA’s work in supporting emerging markets through various disruptive events, including through the COVID-19 pandemic. Furthermore, Leslie detailed that EMTA’s upcoming work will focus on an update of the definitions contained in the template terms and work on benchmark regulation.

Item 4 – Money Market Code

Jon who is a senior adviser in the Bank’s Sterling Markets Division provided an overview of the recent update to the UK Money Market Code (the ’Code’). The updated code was published on 21st April 2021 with accompanying explanatory notes. The Code covers execution of transaction in the deposit markets, specifically in the sterling and foreign currency wholesale unsecured deposit market. The Money Market Committee (the ‘MMC’) of the Bank of England led the review of the 2017 Code. The review focused on a number of themes, including, Diversity & Inclusion, remote working and the electronification of the money markets. The underlying principles of the Code remain unchanged.

The new Code was recognized by the FCA as an industry code and the recognition will remain in place for the next 3 years.

Item 5 - Any other business

The next meeting would be on a date to be announced.


Sharon Blackman (Chair) – Citigroup
Jonathan Grant (Secretary) - Bank of England
Simon Goldsworthy - Deutsche Bank
David Harris - Financial Conduct Authority (FCA)
Tamsin Rolls - JP Morgan
Baljit Saini - NatWest
Rakesh Shah - Standard Chartered
Simon Helm - TP ICAP
Sunil Samani - XTX Markets
Nasia Pachiti Pallikaropoulou – Barclays
Diane Bouwmeester – LCH
Gaynor Wood – CLS
Harkamal Atwal – HSBC
Jateen Shah - Bank of America

FXJSC Legal Sub-Committee Secretariat

Zara Coe – Bank of England
Matthew Hartley – Bank of England

Guest attendees

Grigoria Christodoulou– Bank of England
Leslie Jacobs – EMTA
Jon Pyzer – Bank of England


Dan Parker - Goldman Sachs
Nimisha Kanabar - Morgan Stanley
Richard Lamb - UBS