Currency manipulation and FX spot fixing investigations were initiated in 2013 with the FCA taking the lead amongst global regulators. As a reminder, in November, 2014, the FCA imposed fines totalling over £1.1bn on five banks for failing to control business practices in their G10 spot FX trading operations. The FCA then required over 30 banks and brokers to undertake a detailed assessment of their FX front to back controls, and then formally attest that adequate controls were in place. An important outcome of the above assessments was development of the FX Global Code published in May 2017. This code was a result of work by a group of central banks and market participants from 16 jurisdictions around the globe. The purpose of the Global Code is to promote a robust, fair, liquid, open, and appropriately transparent market in which a diverse set of Market Participants, supported by resilient infrastructure, are able to confidently and effectively transact at competitive prices that reflect available market information and in a manner that conforms to acceptable standards of behaviour. Although the FX Global Code is does not constitute a legal or regulatory obligation, firms would be best advised to perform a gap analysis to avoid any future surprises!