Global Code of Conduct Standards and Practices for the Wholesale Foreign Exchange Market (the “FX Global Code”)

Introduction and Context

On 28 May 2025, the Hong Kong Monetary Authority (HKMA) issued guidance directing Authorized Institutions (AIs) to align with the updated Global Code of Conduct Standards and Practices for the Wholesale Foreign Exchange Market (FX Global Code), following its January 2025 revision by the Global Foreign Exchange Committee (GFXC). The HKMA emphasizes that the updated Code, which refines five principles (9, 10, 35, 50, and 51) to strengthen FX settlement risk mitigation and enhance transparency, has been integrated into the Treasury Markets Association (TMA) Code of Conduct since 2017.

Regulatory Requirements for AIs

Under HKMA Supervisory Policy Manual module CG-6, AIs must maintain adequate control systems to ensure adherence to the FX Global Code as part of the TMA Code. The HKMA requires all AIs to review their FX market practices against the updated Code, implement necessary controls, and renew their Statement of Commitment via the TMA by 24 January 2026. This renewal must reflect the relevance of the 2025 updates to their specific FX activities, with submissions directed to This email address is being protected from spambots. You need JavaScript enabled to view it..

Implementation and Support

The HKMA encourages AIs to promote the updated FX Global Code to relevant counterparties and customers. The TMA, as the local register for Statements of Commitment, fully supports the renewal process. AIs are reminded that the GFXC’s targeted review confirmed the Code remains largely fit for purpose, with the 2025 updates addressing specific operational enhancements without altering the Code’s foundational structure.