Trading platforms must clearly disclose how they use data from client transactions, particularly regarding order handling, fees, and post-trade reviews, according to the updated FX Global Code.
In addition, the updates encourage a “hierarchy of settlement methods” and a risk waterfall approach, to address settlement risk, a significant concern due to increasing off-CLS trades.
The Global Foreign Exchange Committee (GFXC) completed its review of the Code on Friday, January 24.
The December 2024 version of the Code, which will supersede the July 2021 version, updates its principles of good practice in the foreign exchange market in two key areas: one focused on enhancing transparency around certain types of execution activity and the utilization of client-generated FX data, and the other on FX Settlement Risk.
Updates have been made to five of the Code’s fifty-five principles to strengthen the Code’s guidance on FX Settlement Risk, as well as to increase transparency around certain types of FX transactions and the use of client-generated data on electronic trading platforms.

“Settlement risk and liquidity remains one of the most pressing challenges in the FX market, and the updated FX Global Code rightly prioritises its mitigation,” said Basu Choudhury, Head of Trade Lifecycle Strategy, OSTTRA.
“We see this as a pivotal moment to ensure market participants not only manage settlement risk but also optimise their FX liquidity comprehensively,” he told Traders Magazine.
“Only by integrating tools to facilitate full visibility of exposures from point of execution with effective netting protocols and intraday FX payment-versus-payment (PvP) can firms be empowered to navigate future FX settlement challenges with greater confidence and precision,” he added.
As of December 2024, 1,328 entities globally have indicated their adherence to the Code’s principles by signing a Statement of Commitment (SoC). With the publication of the updated Code, the GFXC encourages all market participants to review the amendments and to consider renewing their SoC, taking into account the nature and relevance of the updates to their FX market activities.
The GFXC has given firms a 12-month period to adjust to these changes, designed to improve transparency, efficiency, and risk mitigation in FX markets.

Alex Knight, Head of EMEA at Baton Systems, commented: “The updates to the global FX code are a significant step forward in enhancing transparency and reducing risk in FX markets. It is now incumbent upon firms to use the next 12 months to implement the available solutions to facilitate payment-versus-payment (PvP) settlement.”
“Even where PvP settlements aren’t yet available, most firms still have an opportunity to deploy technology to further de-risk their business through the use of real-time information to track and orchestrate settlements in a controlled manner, and to reduce the volume of business that is settled gross.”
The December 2024 version of the Code will also include new links in its Foreword section that highlight some of the existing GFXC Reports. These reports are intended to facilitate wider awareness and understanding of specific aspects of the FX market and, where relevant, describe how they relate to the Code’s principles.
While these reports are not part of the Code or the SoC, they contain useful explanatory material and offer insight into the practical implementation of the Code principles.
A summary of the outcomes of the 2024 Code Review highlighting the specific changes to the Code is also being published, along with a document that includes the responses received by the GFXC to the Request for Feedback on the proposals to amend the Code and the DCS.
Alongside the revised Code, the Committee will also publish enhanced Disclosure Cover Sheets (DCS) for Liquidity Providers and Platforms.
In addition, the DCS for Liquidity Providers and Platforms were also extended with the objective to enhance transparency and comparability across providers on the use of FX data.
The GFXC met virtually on 5-6 December 2024 to endorse the outcomes of the Code Review. The GFXC Chair, Gerardo García, commented: “In terms of the 2024 Code Review, there has been strong GFXC support for the final proposals of the FX Settlement Risk and FX Data Working Groups. The Code amendments clearly address the concerns that Market Participants and LFXCs expressed during the review process and are consistent with the objective of having a more robust and transparent FX market.”
Client-Centric Product Innovation in Capital Markets: 2025 Outlook
By Monica Summerville, Head of Capital Markets, Celent
For buy side and sell side firms, alike, enhancing the customer experience (CX) is one of the top priorities driving IT strategies. Meeting—or exceeding—client expectations is central to good business. That’s true in capital markets, where focusing on client-centricity and client enablement is essential for effective implementation of tech initiatives, as I’ve addressed before.
This topic is worth an additional look at the start of 2025, when focusing on client-centric product innovation is one of the key business trends driving technology investments in capital markets, as detailed in Celent’s Capital Markets: Technology Trends Previsory 2025. Additional key business trends driving technology investment in capital markets in 2025 include balancing efficiency and innovation (where too much focus on cost-cutting can lead to missed opportunities); building NextGen ecosystems; establishing credibility and value in data; and navigating tactics, risk, and strategy across regulatory regimes.
Keeping a close eye on the possibilities for improved customer experience—and how investing in technology enables these enhancements—will always be valuable.
Technologies Converge to Support Client-Centricity
Today we’re seeing a convergence around emerging technologies, cloud computing, and data initiatives. Cloud adoption is high, with investment technology ecosystems migrating to the cloud, service providers consolidating data onto cloud infrastructures, and confidence growing as banks build cloud expertise and embrace cloud delivery models. Cloud is also an emerging technology enabler, such as for artificial intelligence (AI), quantum, and blockchain. As these new technologies come together, they can facilitate everything from new business approaches to new product and service proposition, digital interaction channels, and personalization of client relationships.
To ensure effective initiatives while embracing new technologies for the purpose of supporting client-centric product innovation, the imperative for a new approach is also becoming clear: financial institutions must de-silo their tech stacks and their “tech thinking.” Whereas before there may have been separate groups working on separate initiatives, firms are finding that they must bring these areas together to unlock the usefulness from their technologies. Similarly, firms are creating next generation data ecosystems which bring together sourcing, storage, management, analytics, and advanced technologies. to help facilitate initiatives.
Sell Side Client-Centricity
Source: Celent
The sell side is doubling down on digitization and tech-enabled differentiation to drive client-centric product innovation. Leading investment priorities, as found in Celent’s 2024 Dimensions: IT Pressures & Priorities research include digital assets/crypto assets/tokenization; client/regulatory reporting; research services; environmental, social, and governance (ESG) and sustainability; and origination. Some ways that firms are taking action on these initiatives for digitalization include:
Client-centric product innovation provides a range of opportunities. Firms can embrace opportunities to focus on unstructured data to improve communications. With great potential for both back office (where emails and faxes are still prevalent) and front offices. Emerging technologies, especially some of the new AI offerings, support opportunities for new products around data transfer, which leverage automation, to streamline and improve communications, and shorten onboarding cycles.
Firms also have new opportunities to cross-sell by focusing more holistically on the client. Technology now makes it possible for areas within a firm, which were once separated and operated as silos, sometimes for regulatory reasons, to be cross-sold. New technology taps into the potential to leverage adjacencies through cross-selling and up-selling at the group level, between banking units, while remaining compliant with securities, market abuse, and privacy rules. Examples here may include across: asset and liability management (ALM) and treasury and markets, looking at flow; wealth management and capital markets, for structured products, issuance, and product placements; transaction banking and capital markets, looking at foreign exchange (FX) or interest rate derivatives; or asset servicing and capital markets, in areas like collateral management and FX.
Buy Side Client-Centricity
Source: Celent
Similarly, as our team has found, the buy side is putting new energy into client-centric product innovation. Firms here are evolving from traditional analog distribution models to digitally-enabled strategies to engage advisors, allocators, and other intermediaries using technological capabilities, insights, content, and analytics. Various firms are building out digital channel capabilities and partnerships, such as product/service customization initiatives, new hybrid public/private product launches, and new opportunities for private asset investing in retail and defined contribution (DC) pensions.
What we’re likely to see in the coming year on the buy side will include scaled product innovation and hyper customization, which is becoming a core capability. Firms will look to enhance capabilities for faster product innovation and customization, aiming to counteract the ongoing pressures on margins. By developing tailored investment products and swiftly adapting to market demands, firms can differentiate themselves and attract a broad client base and ultimately improve profitability.
This emphasis on innovation will help mitigate margin compression, also allowing firms to better align offerings with the evolving needs of investors. Traditional and alternative investment managers are taking action around the expansion of private assets into non-institutional segments, such as defined-contribution pensions, private banks, wealth managers, and independent financial advisors that service a more retail-oriented client base. By expanding offerings to include alternative investments (private equity, credit, hedge funds, real estate, and other non-traditional assets), firms can cater to a wider-range of clients while seeking diversification and enhancing returns beyond traditional asset classes.
Private credit crossovers and collaborations, between banks and alternative/private credit managers, are set to grow. These are becoming increasingly prominent. As firms navigate the complexities of these opportunities and some of the involved risks, emphasis on digitization will likely grow as a means to optimize the private credit operations in terms of greater automation, efficiency, and more accurate information exchanges across the multiple participants.
Plan for Uncertainty, While Focusing on Client Needs
Technology needs to support capital markets firms, no matter what is thrown at them in the coming year. For a business to be agile, it must plan for uncertainty, all while embracing the technology that can not only support innovation goals, but meet current and prospective clients’ needs.