On 16 Jun 2025, the HKMA reminded Approved Money Brokers to align with the GFXC's updated FX Global Code, which refined five principles to strengthen settlement risk mitigation and enhance transparency. AMBs must renew their Statement of Commitment to comply with the TMA Code, as the updated FX Global Code forms part of their regulatory obligations under the Banking Ordinance.
This article was generated using SAMS, an AI technology by Timothy Loh LLP.
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Introduction
On 16 Jun 2025, the Hong Kong Monetary Authority (HKMA) issued a circular to Approved Money Brokers (AMBs) regarding the updated Global Code of Conduct Standards and Practices for the Wholesale Foreign Exchange Market (FX Global Code), following its latest revision by the Global Foreign Exchange Committee (GFXC) on 24 January 2025.
Key Updates to the FX Global Code
The GFXC refined five principles (#9, #10, #35, #50, and #51) of the FX Global Code after a targeted review and public consultation, strengthening guidance on FX settlement risk mitigation practices and enhancing transparency around specific execution activities and FX data utilisation. These updates reflect the GFXC's assessment that the Code remains largely fit for purpose, with the revisions addressing targeted areas of market practice.
Compliance Requirements for AMBs
As the FX Global Code has been incorporated into the Treasury Markets Association (TMA) Code of Conduct and Practice since 2017, AMBs are required to align their practices with the updated principles to maintain compliance with the TMA Code. AMBs must review their operations in light of the revisions, renew their Statement of Commitment (as specified in Annex 3 of the FX Global Code), and submit it to the TMA at
Additional Guidance
The HKMA encourages AMBs to promote the updated FX Global Code to relevant clients and ensure its applicability to their FX market activities. The Treasury Markets Association fully supports the renewal of the Statement of Commitment, and AMBs are reminded that adherence to the TMA Code—including the incorporated FX Global Code—is a condition of their approval under section 118C of the Banking Ordinance.
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