The London Foreign Exchange Joint Standing Committee (FXJSC) Legal Sub-committee convened on March 5, 2025, at the Bank of England. James Brennan chaired the meeting in Sharon Blackman's absence.
The minutes from the previous meeting on November 26, 2024, were approved. Peter Bevan and Simon Treacy from Linklaters provided an update on the regulatory framework affecting the FX market. They highlighted ongoing regulatory changes and increasing jurisdictional divergence, with a focus on both retail and wholesale markets.
Key topics discussed included MiFID II/MiFIR issues such as post-trade reporting and order execution policies. Concerns about market abuse related to pre-hedging were raised, with an IOSCO report expected later in the year to provide further insights.
Regarding EU regulations, CRD6's impact on cross-border business was noted, with tighter restrictions for banks providing services into the EU. The UK is developing a licensing regime for cryptoassets under existing frameworks like anti-money laundering.
Financial crime remains a priority for enforcement by the FCA, with new fraud strategies anticipated. The Economic Crime and Corporate Transparency Act 2023 aims to address corporate fraud and economic crime failings.
In AI regulation, the UK maintains a principles-led approach rather than broad regulations like those in the EU. Expectations for regulated sectors remain high with continued focus on AML systems and controls.
The sub-committee also discussed ISDA’s FX definitions and suggested future presentations by ISDA representatives. Implementation of changes to the Global Code was another topic of interest.
Future meetings will cover topics such as EU Benchmarks regulation exemptions and Global Code requirements implementation.
Attendees included representatives from Deutsche Bank, Financial Conduct Authority, London Stock Exchange Group, JP Morgan Chase, NatWest, Standard Chartered, Goldman Sachs, UBS, CLS FXJSC Legal Sub-Committee Secretariat members from Bank of England, and guest attendees from Linklaters. Apologies were noted from several members including Sharon Blackman of Citigroup.
Information from this article can be found here.