Bank Of England: Minutes Of The London FXJSC Legal Sub-committee Meeting – 17 September 2025

Minutes

Minute 1: Introduction

The Chair (Sharon Blackman) opened the meeting, welcoming those online and in person.

Minute 2: Minutes

As the 24 June 2025 meeting minutes were circulated late, members were asked to email any questions to the Chair and Bank Secretariat after the meeting, as no comments were received, they were deemed to be approved.

Minute 3: FXJSC Operations Sub-Committee contingency planning

Matthew Hartley (MH) (Bank of England) gave an update regarding the recent discussions that have taken place at the Operations Sub-Committee (OSC). The OSC discussed contingency plans for a specific scenario relating to Sterling settlement issues. The proposal from the OSC was to create a triage process following an alert of a potential issue.

The process will be:

• Upon incident notification, a core group will validate it and assess its significance and determine if the OSC or a part of the OSC should convene.
• If a meeting is held, the OSC will confirm the event and review market communications.

The FXJSC LSC observed that broader market notifications should take into account Market Abuse Requirements and competition considerations when determining timing.

Minute 4: MiFID3

Tom Harkus (TH) (Simmons & Simmons LLP) gave a MiFID II/MiFIR Regulatory Update and discussed the below topics.

1. Dark Trading – Volume Cap
2. Pre-Trade Transparency (Non-Equity Instruments)
3. Post-Trade Transparency (Derivatives)
4. Business Clock Synchronisation
5. Consolidated Tape Provider (CTP) – OTC Derivatives
6. Transaction Reporting
7. Post-Trade Risk Reduction Services (PTRRS)
8. Dealing on Own Account
9. Systematic Internaliser (SI) Definition
10. Best Execution

Minute 5: Topics for discussion at future meetings

It was proposed that a joint meeting between OSC and LSC should be scheduled for November to talk through the comms plan.

The Committee recommended discussing ISDA FX definitions changes at the November joint meeting as well.

Further suggestions included:

• Examine AI's influence on the FX market.
• Pre-Hedging Discussion (Based on IOSCO’s Discussion Paper).
• US policy changes and FX swaps reporting impacting venue boundaries, with UK responses reflecting global market dynamics.
• Benchmark regulations in Europe especially target FX swaps, as the EU aims to exclude them from benchmark scope unless deemed systemically important.
• Discussing mood on T+0 (trade date) and its impact on the market, especially in legal, compliance, or risk contexts.
• Digital assets had been discussed previously but the conversation continues to move forward, and there could be further discussion of how they might reshape FX settlement in future.

Minute 6: Any other business

The Chair raised the possibility of introducing a co-chairing arrangement. While no decision has been made yet, expressions of interest (EoIs) for the role are welcome. Having a co-chair could be beneficial in terms of sharing responsibilities and workload. MH noted that the OSC currently uses a similar model.

The Terms of Reference (ToR) will need to be reviewed accordingly, so any feedback on any other section of the ToRs should be sent to the Bank Secretariat team.

Attendees

Sharon Blackman (Chair) – Citigroup

David Harris – Financial Conduct Authority

Simon Goldsworthy – Deutsche Bank

Joanne Napleton - London Stock Exchange Group

Tamsin Rolls – JP Morgan Chase

Mayank Patel – Bank of America

Rakesh Shah – Standard Chartered

Baljit Saini – NatWest

FXJSC Legal Sub-Committee Secretariat

James Brennan – Bank of England

Matthew Hartley – Bank of England

Carly Jones – Bank of England

Guest attendees

Tom Harkus - Simmons & Simmons LLP

Apologies

Gaynor Wood – CLS

Harkamal Singh Atwal – HSBC

Krisha Somaiya – UBS

Nimisha Kanabar - Morgan Stanley

Rowland Stacey – Goldman Sachs

Sunil Samani - XTX Markets