Minutes of the London FXJSC Legal Sub-committee – 28 February 2023

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 06 July 2023

28 February 2023

Time: 3pm– 4.30pm | Location: Video meeting


Minute 1 – Introduction and Minutes

The minutes of the meeting of 15 November 2022 were approved.

Minute 2 – Discussion on Regulatory Outlook

Peter Bevan and Simon Treacy from Linklaters LLP gave an overview of the current regulatory framework and some views for the future and how it will affect the FX market. This included developments on the FX Global Code, FCA enforcement, FCA exploration of high frequency traders in the FX markets, UK cryptoasset regulation, CBDCs, ESG, regulatory focus on risk management, the Financial Services and Markets Bill 2023 and FCA Consumer Duty.

Minute 3 – Discussion on potential changes to the Sub-Committee’s Terms of Reference

Matthew Hartley gave a brief overview on the Main Committee’s plans. The Main Committee is looking to make some further changes to its terms of reference. Accordingly, it was agreed that it would be sensible to wait for the Main Committee to finalise its terms of reference before the Legal Sub-Committee’s terms of reference are updated, to ensure consistency. As soon as the Main Committee has approved its new terms of reference, the Legal Sub-Committee members can discuss appropriate changes at the next Legal Sub-Committee meeting in June.

Minute 4 – Discussion on potential topics for FXJSC Legal Sub-Committee

The Legal Sub-Committee members discussed potential topics for upcoming committee meetings. Diane Bouwmeester viewed the regulatory updates as positive and noted that a lot of new regulation is likely to be introduced this year and suggested review of specific topics more frequently rather than annually. Sharon Blackman suggested discussing the proposed refresh of the FX definitions by ISDA and the EMTA outreach. In light of this, Sharon suggested it would be useful to have an ISDA member join a committee meeting to speak about their FX agenda. Sharon noted that she will be conducting her periodic outreach to the Legal Sub-Committee members individually.

Minute 5 – Any other business

There was no other business to discuss.


Sharon Blackman (Chair) - Citigroup

George Johnston (Secretary) - Bank of England

Sunil Samani - XTX Markets

Rowland Stacey - Goldman Sachs

Mayank Patel – Bank of America

David Harris – Financial Conduct Authority

Simon Goldsworthy – Deutsche Bank

Gaynor Wood – CLS

Diane Bouwmeester – London Stock Exchange Group

FXJSC Legal Sub-Committee Secretariat

Matthew Hartley – Bank of England

Ayodele Cameron – Bank of England

Guest attendees

Peter Bevan – Linklaters LLP

Simon Treacy – Linklaters LLP


Tamsin Rolls – JP Morgan Chase

Nimisha Kanabar – Morgan Stanley

Simon Helm – Tullet Prebon

Richard Lamb – UBS

Rakesh Shah - Standard Chartered

Harkamal Singh Atwal – HSBC

Baljit Saini – Natwest