The foreign exchange industry (“forex” or “FX”), a seemingly ever-growing massive liquid market accessible to many kinds of market participants, has finally started showing signs of a slowdown. In 2016, the world’s largest financial market posted a decline for the first time in 15 years, with trading volumes down amid industry challenges in light of increased regulatory scrutiny. Forex market professionals have cited common sense reasons for the slump, such as difficult trading conditions and the rise in passive management, but the recent regulatory settlements and pleas may also be a factor.

Amid this environment, the Bank for International Settlements (“BIS”) established the Foreign Exchange Working Group (FXWG) in July 2015 to strengthen code of conduct standards and principles in forex markets in the form of a “Global Code.” The stated purpose is both ambitious and laudable—“desire to promote integrity and restore confidence in the wholesale foreign exchange market (FX market) in light of the recent cases of misconduct.”