4. Information Sharing

INFORMATION SHARING

LEADING PRINCIPLE:

Market Participants are expected to be clear and accurate in their communications and to protect Confidential Information to promote effective communication that supports a robust, fair, open, liquid, and appropriately transparent FX Market.

I. Handling Confidential Information ¹

PRINCIPLE 19

Market Participants should clearly and effectively identify and appropriately limit access to Confidential Information

Market Participants should identify Confidential Information. Confidential Information includes the following information not in the public domain received or created by a Market Participant:

FX Trading Information. This can take various forms, including information relating to the past, present, and future trading activity or positions of the Market Participant itself or of its Clients ²Client: A Market Participant requesting transactions and activity from, or via, other Market Participants that provide market making or other trade execution services in the FX Market. A Market Participant can act as a Client in some instances while making markets in other instances, as well as related information that is sensitive and is received or produced in the course of such activity. Examples include but are not limited to:
- details of a Market Participant’s order book
- other Market Participants’ Axes ³
- spread matrices provided by Market Participants to their Clients
- orders for benchmark fixes
Designated Confidential Information ⁴. Market Participants may agree to a higher standard of non-disclosure with respect to confidential, proprietary, and other information, which may be formalised in a written non-disclosure or a similar confidentiality agreement.

Identification of Confidential Information should be in line with any legal or contractual restrictions to which the Market Participant may be subject.

Market Participants should limit access to and protect Confidential Information.

Market Participants should not disclose Confidential Information except to those internal or external parties who have a valid reason for receiving such information, such as to meet risk management, legal, and compliance needs.
Market Participants should not disclose Confidential Information to any internal or external parties under any circumstances where it appears likely that such party will misuse the information.
Confidential Information obtained from a Client, prospective Client, or other third party is to be used only for the specific purpose for which it was given, except as provided above or otherwise agreed with a Client.
Market Participants should disclose at a high level how Confidential Information, in the form of FX Trading Information, is shared internally in accordance with this Principle.
Market Participants acting as Prime Brokers ⁵Prime Broker (PB): An entity that provides credit intermediation to one or more parties to a trade based on pre-agreed terms and conditions governing the provision of such credit. The Prime Broker can also offer subsidiary or allied offerings, including operational and technology services should have an appropriate level of separation between their prime brokerage business and their other sales and trading business.
- To avoid any potential conflict of interest, a Prime Broker should have appropriate information barriers in place.
- Prime Brokers should be transparent as to the standards ⁶ they require and adopt.

Operators of trading platforms that feature tags should ensure that the practice of “re-tagging” is fit for purpose, and not used to facilitate trading among participants where one party has already previously requested to avoid facing another.

For a discussion of Market Colour ⁷, please see Principle 22.

PRINCIPLE 20

Market Participants should not disclose Confidential Information to external parties, except under specific circumstances.

Market Participants should disclose Confidential Information only under certain circumstances. These may include, but are not limited to, disclosure:

to Agents ⁸, market intermediaries (such as brokers or trading platforms), or other Market Participants to the extent necessary for executing, processing, clearing, novating, or settling a transaction
with the consent of the counterparty or Client
required to be publicly disclosed under Applicable Law ⁹, or as otherwise requested by a relevant regulatory or public authority
as requested by a central bank acting for policy purposes
to advisors or consultants on the condition that they protect the Confidential Information in the same manner as the Market Participant that is disclosing the Confidential Information to such advisors or consultants

Market Participants may actively choose to share their own prior positions and/or trading activity so long as that information does not reveal any other party’s Confidential Information and the information is not shared in order to disrupt market function or hinder the price discovery process, or in furtherance of other manipulative or collusive practices.

Market Participants should only ask for Confidential Information where it is appropriate to do so consistent with Principle 20.

When determining whether to release Confidential Information, Market Participants should take into account Applicable Law, as well as any agreed-to restrictions that may limit the release.

II. Communications

PRINCIPLE 21

Market Participants should communicate in a manner that is clear, accurate, professional, and not misleading.

Communications should be easily understood by their intended recipient. Therefore, Market Participants should use terminology and language that is appropriate for the audience and should avoid using ambiguous terms. To support the accuracy and integrity of information, Market Participants should:

attribute information derived from a third party to that third party (for example, a news service)
identify opinions clearly as opinions
not communicate false information
exercise judgement when discussing rumours that may be driving price movements, identify rumours as rumours, and not spread or start rumours with the intention of moving markets or deceiving other Market Participants
not provide misleading information in order to protect Confidential Information—for example, when executing partial orders. Accordingly, Market Participants could, if asked, decline to disclose whether their request to transact is for the full amount rather than inaccurately suggest that it is for the full amount.

Market Participants should be mindful that communications by personnel reflect on the firm they represent as well as the industry more broadly.

PRINCIPLE 22

Market Participants should communicate Market Colour appropriately and without compromising Confidential Information.

The timely dissemination of Market Colour ¹⁰ between Market Participants can contribute to an efficient, open, and transparent FX Market through the exchange of information on the general state of the market, views, and anonymised and aggregated flow information.

Firms should give clear guidance to personnel on how to appropriately share Market Colour. In particular, communications should be restricted to information that is effectively aggregated and anonymised.

To this end:

communications should not include specific Client names, other mechanisms for communicating a Client’s identity or trading patterns externally (for example, code names that implicitly link activity to a specific Market Participant), or information specific to any individual Client
Client groups, locations, and strategies should be referred to at a level of generality that does not allow Market Participants to derive the underlying Confidential Information
communications should be restricted to sharing market views and levels of conviction, and should not disclose information about individual trading positions
flows should be disclosed only by price range and not by exact rates relating to a single Client or flow, and volumes should be referred to in general terms, other than publicly reported trading activity
option interest not publicly reported should only be discussed in terms of broadly observed structures and thematic interest
references to the time of execution should be general, except where this trading information is broadly observable
Market Participants should take care when providing information to Clients about the status of orders (including aggregated and anonymised Fixing Orders ¹¹) to protect the interests of other Market Participants to whom the information relates (this is particularly true when there are multiple orders at the same level or in close proximity to one another)
Market Participants should not solicit Confidential Information in the course of providing or receiving Market Colour
operators of trading platforms that feature tags should only disclose user information (colour) that has been clearly stated in their disclosure documents (including rulebooks, guidelines, etc.)
if feasible, anonymous trading platforms should strive to make available to users whether a counterparty or potential counterparty to a trade has represented that it has signed a Statement of Commitment to the current version of the FX Global Code. ¹²

See Annex 1 for a set of stylised examples of Market Colour communications

PRINCIPLE 23

Market Participants should provide personnel with clear guidance on approved modes and channels of communication.

Market Participants should communicate with other Market Participants through approved methods of communication that allow for traceability, auditing, record keeping, and access control. Standards of information security should apply regardless of the specific mode of communication in use. Where possible, Market Participants should maintain a list of approved modes of communication and it is recommended that communication channels on sales and trading desks be recorded, particularly when being used to transact or share Market Colour. Market Participants should give consideration, under exceptional circumstances (for example, in an emergency and for business continuity purposes), to allowing the use of unrecorded lines but should provide guidance to personnel regarding any permitted use of such unrecorded lines or devices.

1
Confidential Information: Information that is to be treated as confidential, including FX Trading Information and Designated Confidential Information ↩︎
2
Client: A Market Participant requesting transactions and activity from, or via, other Market Participants that provide market making or other trade execution services in the FX Market. A Market Participant can act as a Client in some instances while making markets in other instances ↩︎
3
Axe: An interest that a Market Participant might have to transact in a given product or currency pair at a price that may be better than the prevailing market rate ↩︎
4
Designated Confidential Information: Confidential, proprietary, and other information for which Market Participants may agree to a higher standard of non-disclosure, which, at their discretion, may be formalised in a written non-disclosure or similar confidentiality agreement ↩︎
5
Prime Broker (PB): An entity that provides credit intermediation to one or more parties to a trade based on pre-agreed terms and conditions governing the provision of such credit. The Prime Broker can also offer subsidiary or allied offerings, including operational and technology services ↩︎
6
Standards: A Market Participant’s internal policies, external codes (the FX Global Code and any annexes to the Code published by regional FX committees or jurisdictions in which the Market Participant is based or operating), and other relevant guidance (for example, guidance provided by public sector international organizations such as the Bank for International Settlements and the Financial Stability Board) ↩︎
7
Market Colour: A view shared by Market Participants on the general state of, and trends in, the market ↩︎
8
Agents: A Market Participant that executes orders on behalf of its Clients pursuant to the Client mandate, and without taking on market risk in connection with the order ↩︎
9
Applicable Law: With respect to a Market Participant, the laws, rules, and regulations applicable to it and the FX Market in each jurisdiction in which it does business ↩︎
10
Market Colour: A view shared by Market Participants on the general state of, and trends in, the market ↩︎
11
An order to transact at a particular fixing rate ↩︎
12
The responsibility of conveying accurate and up-to-date Statement of Commitment signatory status to the platform falls entirely on the user, whereas the platform is responsible only for storing and reporting this information as presented by that user and is not making any representation regarding the conduct of the user. Should there be any changes to the Statement of Commitment status of the user, the obligation is on the user to update the platform with that information. ↩︎

2025 Online FX Global Code