groups of the gfxc, drawing on a diverse group of market participants and central banks, have been working on the review. the proposed updates to the code have been through a number of rounds of feedback with market participants through the fxcs round the world, as well as a public feedback process. i would like to thank the broad range of market participants who provided us with feedback. i would particularly like to thank the working groups for their hard work, especially given the challenging environment of the pandemic. the review of the code following this process of review and consultation with industry, the gfxc has published the updated version of the code. the july 2021 version of the code replaces the earlier, august 2018 version. in total, 11 of the code ’ s 55 principles have been amended. the gfxc has also developed disclosure cover sheets and templates for algo due diligence and transaction cost analysis ( tca ) to assist market participants in meeting the code ’ s principles for disclosure and transparency. additionally, the gfxc has published guidance papers on the practices of pre - hedging and last look to support market participants in applying the code ’ s principles in these areas. one area that reflects the development of the market is the role played by anonymous trading. the code has been amended to encourage greater disclosure by those operating anonymous platforms, including of their policies for managing the unique identifiers ( ‘ tags ’ ) of their users. anonymous trading platforms are also encouraged to make available the code signatory status of their users. recognising the value that data related to trading activity holds for market participants, the code now states that fx e - trading platforms ( including anonymous platforms ) should be transparent about their market data policies, including which user types such data is made available to and at what frequency and latency. platforms are also encouraged to disclose the mechanisms and controls by which they are managing or monitoring the credit limits of their users. the risks associated with fx settlement are potentially very significant and have come back into view again following the publication of the previous triennial survey of fx turnover by the bis. 4 consequently, the gfxc identified a need to strengthen the code ’ s guidance on 2 / 4 bis central bankers'speeches settlement risk. amendments have been made to place greater emphasis on the usage of payment versus payment ( pvp ) settlement mechanisms where they are available and to provide more detailed guidance on the management of settlement risk where pv

execution including e - trading and platforms, prime brokerage, governance, risk management and compliance, and confirmation and settlement. the code is principles - based rather than rules - based. there are a number of reasons why this is so but, for me, an important reason is that the more prescriptive the code, the easier it is to get around. rules are easier to arbitrage than principles. the more prescriptive and the more precise the code, the less people will think about what they are doing. if it ’ s principles - based and less prescriptive then market participants will have to think about whether their actions are consistent with the principles of the code. the code is not a procedures manual. rather, the code articulates principles that need to be taken into account. individual firms may then take these principles and reflect them in their own procedures manuals. our aim in setting out these principles is to provide market participants with the framework in which to think about how they, for example, handle their orders. the emphasis here is very much on the word ‘ think ’. 1 / 4 bis central bankers'speeches these principles of good practice have helped to restore confidence and promote the effective functioning of the wholesale fx market. in my view, the fx market is in a better place than it was a few years ago. that is confirmed by surveys of market participants too, including the one conducted by the gfxc a couple of years ago. the code has also been adopted by a number of securities regulators round the world as the primary reference for their oversight of the fx market, including in the uk, in china and in my own market australia. when we launched the code, it was agreed that the code would be reviewed by the gfxc every three years to ensure it remained appropriate and to also ensure it stayed current with the ongoing evolution of the fx market. hence, around two years ago, the gfxc surveyed market participants to assess what areas of the code needed to be reviewed. 2 the primary response of market participants was that the code remained fit for purpose and changes should only be made as necessary. the strong guidance was that changes to the code should be contained to a few areas. the gfxc identified a few key areas requiring review to ensure that the code continues to provide appropriate guidance and contributes to an effectively functioning market, and remains in step with the evolution of the market. 3 over the past 18 months, various working