We signed the FX Global Code. Why are other signatures missing?

Ian Battye, Chief Investment Officer, Currency
Ian Battye, Chief Investment Officer, Currency

In the current environment, where every day appears to bring a new set of regulations, it may appear strange that Russell Investments is actively embracing a new set of measures, referred to as the FX Global Code, focused upon the global foreign exchange marketplace.

It’s not strange at all. We believe FX providers should act in a fiduciary manner for their clients. The code embraces that. So, as you can see in the photo, we signed it. I personally put my name to the paper. A key question might be: Why are other FX providers unwilling to sign?


What the Code says

We believe the FX Global Code is an important document. It’s simply a set of principles of good practice in the foreign exchange marketplace. It was developed to provide a common set of guidelines that promote the integrity and effective functioning of the wholesale foreign exchange market. The Code was developed through a partnership of central banks and market participants from around the globe.

The purpose of the Global Code is to promote a robust, open, and appropriately transparent market. With that purpose in mind, it seems self–evident that Russell Investments would be one of the first asset managers globally to sign. And it seems equally evident that those who haven’t yet signed the Code should be questioned.

The Code advocates a diverse set of market participants, supported by resilient infrastructure, who are able to confidently and effectively transact at competitive prices that reflect available market information. Their transactions should occur in a manner that conforms to acceptable standards of behavior. The Code addresses a broad set of issues relevant to foreign exchange market participants such as ethics, governance, execution, information sharing, risk, compliance, confirmation and settlement.

Why we signed it

As a leading global provider of passive and dynamic currency overlay and agency currency execution, robustness and transparency have long been bywords for Russell Investments’ foreign exchange services. These are characteristics much sought after by consumers of foreign exchange services globally. So Russell Investments was delighted to sign the Code as a signal of our compliance and support for the principles it contains.

As a signatory to the Code, we’ve undertaken a thorough review of all 55 principles contained in it and made the assessment, where relevant, that we are fully compliant. It’s important to note that the Code does not impose legal or regulatory obligations on market participants. Nor does it substitute for regulation. Instead, it’s intended to serve as a supplement to any and all local laws, rules and regulations by identifying global good practices and processes. Its existence is a sign of maturity in the foreign exchange marketplace that has been plagued in recent years by scandals and examples of practices that fall far short of a fiduciary standard.

Why are others refusing?

In short, the Code provides those signing with a tangible way to express their support for global best practices and transparency in the foreign exchange marketplace. Thought of in that way, it begs the question: Why wouldn’t all providers of foreign exchange services sign the Code as a means of demonstrating their commitment to and ability to deliver best practice?

Signing makes sense. Failing to sign? Not so much.


These views are subject to change at any time based upon market or other conditions and are current as of the date at the top of the page.

Investing involves risk and principal loss is possible.Past performance does not guarantee future performance.Forecasting represents predictions of market prices and/or volume patterns utilizing varying analytical data. It is not representative of a projection of the stock market, or of any specific investment.

This material is not an offer, solicitation or recommendation to purchase any security. Nothing contained in this material is intended to constitute legal, tax, securities or investment advice, nor an opinion regarding the appropriateness of any investment, nor a solicitation of any type.

The general information contained in this publication should not be acted upon without obtaining specific legal, tax and investment advice from a licensed professional. The information, analysis and opinions expressed herein are for general information only and are not intended to provide specific advice or recommendations for any individual entity.

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Russell Investments’ ownership is composed of a majority stake held by funds managed by TA Associates with minority stakes held by funds managed by Reverence Capital Partners and Russell Investments’ management.

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