Minutes of the Meeting of the Court of Directors held on 22 May 2024

Minutes of the Meeting of the Court of Directors held on 22 May 2024


David Roberts, Chair

Andrew Bailey, Governor

Sarah Breeden, Deputy Governor – Financial Stability

Ben Broadbent, Deputy Governor – Monetary Policy

Sir Dave Ramsden, Deputy Governor – Markets & Banking

Sam Woods, Deputy Governor – Prudential Regulation

Jonathan Bewes

Sabine Chalmers

Lord Jitesh Gadhia

Anne Glover

Sir Ron Kalifa

Diana Noble

Frances O’Grady

Tom Shropshire

In attendance:

Ben Stimson, Chief Operating Officer


Sebastian Walsh

1. Enforcement Decision Making Committee (EDMC) – Report to Court

(Sir William Blair, Duncan Cromarty and David Friar)

The Chair welcomed William Blair to the meeting and thanked him for his leadership of the EDMC.

William Blair updated Court on the EDMC’s activities over the past year. The EDMC had recruited three new Members to the Committee since the last update to Court. He noted that the expansion of the Bank’s statutory responsibilities as a result of the Financial Services and Markets Act (2023) was likely to increase the workload of the EMDC, notably to include Financial Markets Infrastructures.

William Blair also informed Court that the EDMC had been working with the PRA on how to expedite settlements. Court discussed the importance of firms understanding this option was available. He added that the Terms of Reference of the EDMC had been updated for the first time since establishment in 2018, to incorporate a pause in EDMC proceedings to allow for settlement arrangements.

In response to questions, it was clarified that the EDMC would have nine Members for a period of time before falling to six. The Chair observed that the membership of the EDMC was balanced and that the new Members brought valuable, broad skills to the Committee.

2. Conflicts, Minutes and Matters Arising

There were no conflicts declared in relation to the present agenda.

The minutes of the meeting held on 11 April 2024 were approved.

Sebastian Walsh notified Court that the next release of historic Court Minutes would be published alongside the Minutes of this meeting.

The Chair invited comments on Court’s forward agenda. Diana Noble asked that the Communications directorate return to Court following communication of the Bank’s pension review proposals, to inform Court regarding staff views.

The Chair also expressed his thanks to Ben Broadbent, who was attending his final meeting of Court, for his service to the Bank and the United Kingdom.

3. Governor’s Update

The Governor noted the latest fall in inflation, and observed there would be a number of data releases prior to the next MPC decision. He noted that ongoing challenges surrounding the production of labour force data by the ONS continued to pose a major difficulty for the MPC, but that agency intelligence indicated that while pay settlements remained elevated firms were not now passing as much of those costs through to customers.

The Governor reflected on the Bernanke Review and its importance, noting to Court that the immediate priority for the Bank would be making progress in updating FAME and accompanying systems, where work was under way.

The Governor noted that Liz Oakes – recently appointed as an external member to the FPC – had appeared before the Treasury Select Committee (TSC). The Chair of the TSC had written to the Governor to express concerns about the appointment process, with particular regard to how recusals were applied should an appointee have a real or perceived conflict of interest. He had replied to the TSC outlining the rigour of the Bank’s process.

4. Audit and Risk Committee (ARCo) Update

Jonathan Bewes updated Court on the work of ARCo, which had met on 13 May.

ARCo had been updated on progress being made with regards to the Bank’s five-year capital review, undertaken in consultation with HMT.

ARCo had also been updated on the RTGS Renewal Programme, and the Bank’s Cloud Strategy. ARCo agreed with the assessment that Cloud was a vital part of the Bank’s developing technology strategy.

ARCo had been updated on the work of the Change and Planning directorate and had recommended the team focus on increasing assurance and support around high-impact programmes.

ARCo had considered the Bank’s Annual Report and Accounts. Jonathan Bewes was content to recommend to Court that the Bank’s Annual Reports and Accounts should be prepared on a going concern basis and that they would be fair, balanced and understandable.

ARCo was presented with a draft of the Bank’s Climate Change disclosures.

Jonathan Bewes noted that the Bank’s Auditors – the NAO and KPMG – had made good progress with their audits and had not identified any material points of concern.

5. Remuneration Committee (RemCo) Update

Diana Noble updated Court on the work of RemCo, which met on 24 April.

RemCo had discussed the Bank’s plans for its Leeds presence.

RemCo had considered the Remuneration Report within the Bank’s Annual Report and Accounts, as well as the Gender Pay Gap.

RemCo had also approved the arrangements for the end of Ben Broadbent’s term as Deputy Governor.

6. Chief Operating Officer Update

Ben Stimson updated Court on progress in the transformation of Central Services, reflecting on the appointment of a new leadership team. He noted key priorities in the coming months included the pensions review and the Bank’s development of its Leeds operation.

In line with the discussion at the previous ARCo, Court discussed the increasing number of new recruits to the Bank over the past two years. Court requested an analysis of the experience of external recruits in the second half of the year.

Turning to investment planning, Ben Stimson noted that demand had exceeded supply, as Jo Hill would outline during the next item. Court members observed the Bank’s new Strategic Priorities, in development, must shape decisions.

Ron Kalifa asked that Court be given more information on the framework used to make investment decisions in due course.

Ben Stimson turned to items coming for approval.

Technology Support Services Framework

Court approved the framework, which supported the Bank’s ability to procure third party technology services. Ben Stimson set out that should the framework be utilised; individual contracts would be subject to the Bank’s usual governance processes.

Microsoft Enterprise Agreement

Court approved the item.

7. Investment Portfolio Update

(Jo Hill)

Jo Hill updated Court on work to refine and harmonise the Bank’s investment and change portfolio. Jo Hill said that, while demand continued to exceed available funding, good progress had been made to enhance how programmes are overseen. She also updated Court on the development of her directorate.

Dave Ramsden and Sarah Breeden welcomed the positive cultural change that was emerging around the investment challenge faced across the Bank, with better understanding of dependencies across the organisation.

Court members raised the RTGS Programme and Finance Modernisation Projects as examples where major projects – and decisions taken regarding them – would have substantial implications for decision-making elsewhere in the Bank’s investment portfolio.

The Chair thanked Jo Hill for her work to establish the Change and Planning directorate and recommended that the Bank maintains its focus on scoping programmes effectively, measuring and tracking outputs and associated financial and non-financial benefits.

8. The Bank’s Finances

(Afua Kyei and Kristy Eden-Green)

Afua Kyei introduced the item, noting that the previous financial year had closed with the Bank in a better position that had been forecast.

In response to questions, it was clarified that the Bank had not forecast costs to implement a Central Bank Digital Currency (CBDC), as a final policy decision had not been taken on this work.

Court discussed how the Bank intended to balance spending between the three principal areas where a need for investment was needed: Data, Technology and Property.

The Chair asked the Secretary to schedule a discussion of the Bank’s emerging thinking on the forthcoming 3-year plan including investment prioritisation, proposed run cost development, including proposed approach to efficiency, and high-level options for budget allocations. Court would consider this prior to the final budget guidance being communicated to the Bank towards the end of the year.

Court approved the Bank’s final Budget for the Financial Year 2024/25.

9. Bank of England Annual Report and Accounts

(James Bell, Jessica Beynon, Afua Kyei, Matt Cartledge, Aarti Sharma, Chris Peacock, Richard Faulkner, Ryno Swart – KPMG, Josh Simons, Caspar Siegert and Andrea Rosen)

Afua Kyei set out that ARCo had considered the draft Bank of England Annual Report and Accounts on 13 May, noting that the Bank had reached agreement on all questions posed by KPMG.

Court agreed to delegate approval of the Bank’s Annual Report and Accounts to the Signing Committee.

Court agreed that the Bank’s Annual Report and Accounts should be prepared on a going concern basis.

Court agreed to delegate the signing of the Letter of Representation to David Roberts.

The Chair thanked Finance colleagues involved in the preparation of the Bank’s Annual Report and Accounts.

Court commended KPMG for their services to the Bank, during their time as external auditor of the Bank of England.

The Bank of England’s Climate Disclosures

Josh Simons introduced the item, outlining the Bank’s methodology in calculating its emissions footprint.

Court members noted the important engagement on this subject the Bank had with other central banks.

Court agreed to delegate approval of the Bank’s Climate Disclosures to the Bank’s COO, CFO and Executive Director for International.

The Sterling Monetary Framework (SMF) Annual Report

Andrea Rosen introduced the report.

Court discussed and approved the report. Court also noted that it had received the PRA, BEAPFF and BEALF Annual Reports for information.

10. A 3-year plan to modernise Data and Analytics in the Bank

(James Benford)

James Benford introduced the item and set out progress made since the last update to Court.

Anne Glover and Ron Kalifa offered a number of reflections on work undertaken to date. They noted that while good progress had been made, more could be done to encourage idea generation for the use of Data and Analytics at the Bank. Governors noted that experimentation and ideas generation was happening across the Bank at working level but agreed that more could be done to promote and prioritise this.

Anne Glover and Ron Kalifa suggested that more could be done to highlight the costs and benefits of the programme as well as the dynamics of its work in practice.

Court observed that the enterprise approach being deployed was working and was beneficial for the Bank as a whole. This approach addressed a previous gap of collective oversight and leadership of Data and Analytics at the Bank and was seen to be having an effect on wider work to improve the Bank’s approach to project management.

Court agreed to delegate approval of the external publication of the Bank’s Data and Analytics Strategy to the Governor, the Chair, Ron Kalifa and Anne Glover.

Court requested a further update on the topic at its October meeting, which should be focussed on the topic of experimentation and the future operating model for Data and Analytics across the Bank.

11. Committee Appointments and Conflicts

(Sebastian Walsh)

Sebastian Walsh noted that since the last meeting of Court, Liz Oakes – recently appointed to the FPC – had undertaken her pre-appointment hearing with the Treasury Select Committee.

12. IEO Evaluation of the PRA’s secondary growth and competitiveness objective (SCGO)

(Melissa Davey, Dan Georgescu and David Bailey)

Melissa Davey introduced the item and gave an overview of the review and methodology.

Sam Woods welcomed the IEO’s review and noted its importance, coming shortly after the introduction of this secondary objective. He also informed Court that he was considering giving a speech following the publication of the IEO report, to serve as part of the Bank’s response.

The Governor and Chair agreed it was important that the Bank responds closely and directly to the points made in the IEO review.

Non-executive members of Court said it would be important to demonstrate that the PRA was working differently in some ways, in response to this objective.

The Chair concluded the discussion by noting the importance of the Bank not being the victim of an expectation gap regarding this objective.

Court agreed to delegate approval for the publication of the report to the Chair, the Governor and Deputy Governor for Prudential Regulation.

13. Chair’s effectiveness review of the MPC

The Chair updated Court on the outcome of his annual effectiveness review of the MPC. All Members of the MPC recognised the critical importance of Dr Ben Bernanke’s review and emphasised that the Bank should continue to prioritise its efforts to increase its technology and data capabilities.

The MPC considered the quality of papers and staff analysis to be good.

The Governor welcomed the review, noting the themes from the Chair’s effectiveness review were aligned to that of Dr Ben Bernanke’s review.

14. Support for Monetary Policy: Annual Report to Court 2023/24

(Fergal Shortall and Alan Castle)

Court assessed whether the MPC were in receipt of adequate sectoral and regional data. Court noted the critical role of the Bank’s Agents in delivering this data and observed that MPC members had taken part in a high number of regional visits over the course of the last year. Court confirmed its support for the MPC in this regard.

Court highlighted the importance of this work in the context of the Bank’s wider location strategy.

15. Papers for Information

Court noted:

  • Monetary Policy Committee Report
  • RTGS Programme Renewal Update
  • PRA Annual Report
  • BEAPFF Annual Report and Accounts
  • BEALF Annual Report and Accounts

The meeting of Court was closed.


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Appointment of members of the Enforcement Decision Making Committee

Following an external recruitment process and consultation, the Bank of England (Bank) has appointed three new members to its Enforcement Decision Making Committee (EDMC) taking the total to nine.

The EDMC is the Bank’s decision-making body for contested enforcement cases in the statutory regimes the Bank operates in relation to Prudential Regulation, Financial Market Infrastructures, Resolution and Notes issuance.

David Roberts, the Chair of the Court of the Bank of England, said:

‘I am delighted to welcome the new members of the Bank‘s Enforcement Decision Making Committee. The Committee – which is functionally independent from the Bank’s investigation teams and other Bank staff – takes decisions on any contested enforcement actions. The Committee was established in 2018. Since then, with the passing of the Financial Services and Markets Act 2023, the remit of the Committee has extended to cover all the areas in which the Bank has enforcement powers (Prudential Regulation, Financial Market Infrastructures, Resolution and Note issuances). The appointment of the new members, with their impressive range of the expertise and experiences, reflects the expansion of the breadth of the Committee’s remit’.

Sonya Branch, General Counsel of the Bank of England, said:

‘The appointment of these three additional distinguished experts to oversee contested enforcement decisions once again reinforces the Bank’s commitment to transparency, due process and independent scrutiny across all of the Bank’s enforcement activities’.

About the new members

Harry Matovu KC

Harry Matovu KC is a barrister and King’s Counsel in practice at the English Commercial Bar. He is a senior member of Brick Court Chambers in London, and his practice includes major domestic and international commercial disputes across a wide range of financial services and commercial sectors. He also sits as an arbitrator in major international commercial disputes.

He is a Governing Bencher of the Inner Temple, one of the four Inns of Court which govern the admission of lawyers to the Bar and provide support for barristers and student barristers, and he has previously held several positions in the governance structures of the Bar, including the Bar Council Professional Conduct and Professional Standards Committees. He has served as a Trustee of various charitable organisations, including 10 years as a Trustee and 5 years as Deputy Chair of Chichester Festival Theatre. He is founder and Chair of the Black Talent Charter, an initiative to improve the representation of Black executives and professionals in business and the professions.

Dame Clare Moulder DBE

Dame Clare Moulder DBE is a solicitor who for many years was a partner at the international law firm, Linklaters, advising banks and large companies on a wide range of banking and capital markets transactions and latterly specialising in derivatives and structured products. Dame Clare was appointed a part time judge (recorder) in 2010 and a full-time judge in 2015. In 2017 she became a High Court Judge (KBD) and since retiring in 2022 has continued to sit on a regular basis in the Commercial Court hearing complex commercial disputes often involving financial institutions or firms.

Pauline Wallace

Pauline Wallace is a Chartered Accountant. She currently chairs the UK Endorsement Board which is responsible for the adoption of International Financial Reporting Standards in the UK and sits on the Determinations Panel of The Pensions Regulator. From 2013 to 2019, she was a member of the Regulatory Decisions Committee at the Financial Conduct Authority. Prior to 2013, Pauline was a partner in PwC, initially leading the global financial instruments team and subsequently as the UK head of public policy and regulatory affairs for the firm.

About the EDMC

The outcome of most disciplinary enforcement cases is agreed between the Bank and the relevant firm or individual. However, if a firm or individual decides to contest a case brought by the Bank, the EDMC Chair will convene an EDMC panel of three or more drawn to consider the evidence, hear any representations and make the decision. A full description of the EDMC and its procedure is set out in the EDMC Procedures, published in January 2024.

EDMC members are appointed for a five-year term, and they may be reappointed for a second term. Members can serve a maximum of two terms. The existing six members include: Sir William Blair (EDMC Chair); Baroness Kishwer Falkner; Anne Heal; Mark Hoban; Philip Marsden (EDMC Deputy Chair) and; Edward Sparrow.

Notes to editors

  1. EDMC Procedures – January 2024
  2. The Bank’s Approach to Enforcement – January 2024
  3. CP9/23 – The Bank of England’s approach to enforcement: proposed changes and clarifications | Bank of England – May 2023
  4. The Bank of England’s approach to enforcement: proposed changes to statements of policy and procedure following the Financial Services and Markets Act 2023 | Bank of England – March 2024


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CHAPS payments issue | Bank of England

News release

A global payments issue is affecting the Bank’s CHAPS service and delaying some high value and time-sensitive payments, including some house purchases.

We are mindful of the impact this is likely to have and are working closely with a third party supplier, industry and other authorities to resolve the issue as promptly as possible.

If you are concerned about a CHAPS payment you plan to make or receive today, please contact your bank, or other payment service provider.

Retail payment systems are unaffected so people and businesses can continue to use cash points, card payments and bank transfers as normal.


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Minutes of Money Market Committee meeting – June 2024


Item 1 – Welcome

The Chair thanked members for attending and confirmed that the Minutes of the April 2024 meeting had been published on the Bank’s website.footnote [1]

The Chair welcomed those who were attending as part of the Bank’s Meeting Varied People (MVP) initiative.

Items 2 & 3 – Discussion on Money Market Conditions and the Bank’s future balance sheet

A member of the MMC presented an overview of current market conditions. The presentation covered high level developments across equity, commodity, rates and money markets. This included: the evolution term premia in gilts compared to that of US Treasuries and European Government Bonds; US prime Money Market Fund outflows; and an update on the Rule Book for US mandatory clearing.

Colleagues from the Bank of England presented a summary of recent public communications relating to the Bank’s future balance sheet. This covered how Bank of England reserves had evolved over the past decade and some key considerations for the path ahead as QT and TSFME unwind change the size and composition of the Bank’s future balance sheet. The presentation also touched on the recent uptick in usage of the Short-term Repo (STR) facility which was as seen as intended and expected by the Bank, as had also been reflected in some communications by senior Bank officials.

MMC members widely agreed that the STR is working well and doing its job to smooth volatility in repo rates and keep them close to Bank Rate. Members were clear on the messaging from the Bank that the STR is a routine facility and is being used as intended. Members also noted that STR usage will likely continue to increase, both in terms of volumes and number of participating institutions.

While repo rate volatility has increased as Bank of England reserves have declined, members reiterated that money markets were functioning well with no pressure in longer term funding markets and ample money market capacity. Members noted that recent volatility pointed towards discrete and temporary pockets of illiquidity rather than reserves scarcity. The step higher in SONIA through March and April was noted, as was the fact that the rate has stabilised at around 5.20%. Participants noted that a move higher in SONIA rates could be an early indicator of growing demand for liquidity in the system. Some members also suggested that short-end cross currency moves had been placing some of the upward pressure on repo rates around month-ends.

There was discussion around the level of reserves demanded by banks for transactional and precautionary liquidity needs, known as the Preferred Minimum Range of Reserves (PMRR). While members agreed that the current level of reserves is not yet close to the PMRR, some members expect the likely range at which reserves could ultimately settle could be higher than the most recent £345bn – £490bn output of the assessments from surveyed banks – on the basis that banks may demand reserves over other forms of HQLA (in addition to reserves needed to cover intraday liquidity and LCR outflows).

Members also discussed the potential composition of the Bank’s future balance sheet. One member suggested that in the context of a potential larger proportion of reserves being provided through repo in the future, there could be impacts on SONIA volumes.

Item 4 – Sub-committee Updates

Money Markets Code

One of the Chairs of the UK Money Markets Code Sub-committee informed the MMC that the Code Review (which had been conducted over the last nine months by members of the Sub-Committee and industry experts to ensure the Code remains fit for purpose and evolved in line with market practices and structures) was now complete. They outlined the key changes that would be implemented to the Code, which included the process for UK Market Participants in the event of unplanned bank holidays and unexpected market closures and that UK Market Participants are reminded about the importance of settlement discipline.

The MMC endorsed the changes to the Money Markets Code and agreed for the updated Code to be published on the Bank’s websitefootnote [2].

Fails Working Group

A representative from the Securities Lending Committee provided an update on the work being done by its Working Group on Settlement Efficiency. They informed the MMC that a report on the Working Group’s investigation on drivers and impacts of fails as well as potential solutions relating to settlement failure in the UK securities market, was in its final drafting stages and would be published in the following weeks. Further updates will be provided by the Working Group in Q1 2025 as they track progress of the migration to T+1 settlement in North America.

Item 5 – Migration to T+1 settlement

The MMC discussed T+1 settlement migration in the UK which is currently being explored by the Accelerated Settlement Taskforce at HM Treasury in which the FCA and Bank of England participate as observers. Members discussed how the migration in the US has gone so far which was generally considered to be smooth, albeit noting some frictions in credit markets and relating to cash flow management.

Item 6 – Any other business

A member gave an overview of the key themes that came out of this year’s Association for Corporate Treasurers (ACT) Annual Conference. Overall, attendees appeared more positive about the UK economy relative to recent past, albeit concerns around geopolitical risks remained prevalent. The Conference included a panel session on market codes of practice, which included a discussion around the UK Money Markets Code.

The Chair thanked Jessica Pulay (DMO) for her contributions to the MMC over the past years following the announcement of her new role.

The Chair also thanked members for their time and welcomed any suggestions for future agenda items to be sent to the Secretariat in due course.

Committee attendees

Gordon Lowson – Abrdn
James Winterton – Association of Corporate Treasurers
Ina Budh-Raja – Bank of New York Mellon
Emma Cooper – BlackRock
James Murphy – HSBC
Marije Verhelst – Euroclear
Romain Dumas – UBS
Simon Penn – UBS (Presenter)
Rohan Salah-Ud-Din – UBS (MVP)
Inna Shaykevich – Goldman Sachs
Chris Brown – Insight Investment
John Wherton – LGIM
Scott Creed – Lloyds Bank
Rob McNeil (Alternate)
Alan Williams – Santander UK
Yasmin Absolon – Santander UK (MVP)
Romain Sinclair – Société Générale 
Victoria Worsfold – Surrey Heath Council
John Argent – Tradition
Jessica Pulay – DMO (Observer)
Chris Ryan – DMO (Observer)
Alan Barnes – FCA (Observer)

Bank of England

Andrea Rosen (Chair)
Grace Greer
Tom Archer
Iain Ramsay (Presenter)
Janet Yum
Kirstine McMillan (Presenter)


Nic Erevik – Newcastle Building Society
Tony Baldwin – LCH
Nina Moylett – M&G
Chirag Patel – Rabobank
Oliver Butcher – NatWest Markets
Avi Tillu – PIMCO


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Minutes of the London FXJSC Legal Sub-committee Meeting – 5 March 2024

Time: 3pm – 4.30pm | Location: Bank of England, Threadneedle St, London, EC2R 8AH


Minute 1 – Introduction and Minutes

The minutes of the meeting of 28 November 2023 were approved.

Minute 2: FXJSC Global Code Review (Natalie Lovell)

A survey was carried out at the end of 2023 on the FX Global Code (the Code), including among other local foreign exchange (FX) committees, which confirmed that the Code was fit for purpose. However, there will be a targeted review of the Code with two areas of particular focus: i) FX settlement risk; and ii) enhancing data transparency. The FXJSC members were invited to join the two working groups which were currently being formed to address these two areas. It was noted that the Global Foreign Exchange Committee (GFXC) would be discussing the working groups at the meeting in July which was due to be held in Frankfurt.

The GFXC also agreed that the pre-hedging guidance sat outside the Code and therefore that there was no appetite to either review or transpose the pre-hedging guidance into the Code, but instead to include hyperlinks whilst legal considerations were being explored by the GFXC.

Natalie also noted that in the FX space, pre-hedging had made good progress as a product and there was some consideration around the appropriateness of having guidance run alongside the Code for participants.

Minute 3: Regulatory Update from Allen & Overy (Kate Sumpter, Louise Bralsford and Nick Bradbury)

The group presented on the following five upcoming and evolving projects in the regulatory landscape.

  • The Standardised Approach to Counterparty Credit Risk (SA-CCR)

From 1 January 2022, the UK implemented changes to SA-CRR and in Policy Statement 17/23, the PRA confirmed that further UK amendments should be expected. Whilst limited impact is expected on FX markets, dealers should consider widening spreads, moving to clearing (including the new products on offer around ‘smart clearing’) and counterparty risk mitigation.

  • European Market Infrastructure Regulation (EMIR) 3.0

The European Commission (EC) has proposed making amendments to EMIR to increase resilience and the attractiveness of EU central counterparties (CCPs), with the aim of reducing reliance on third country CCPs. There was provisional political agreement on the amending regulation and directive on 7 February 2024, and final publication in the OJ is expected from May 2024.

The UK has not launched its official review of UK EMIR as part of the Smarter Regulatory Framework (SRF), however, there has been engagement with industry and trade bodies through 2023 and 2024 and UK EMIR will form part of “Tranche 3” of the UK SRF reforms.

As part of the Edinburgh Reforms, the UK established its Accelerated Settlement Taskforce (AST) in December 2022. In December 2023, the Chair of the AST provided an update on the work to date and expectations for 2024, including the key objectives, which are: exploring the case for moving to an accelerated settlement cycle, i.e. T+1, in the UK; evaluating current settlement performance across the UK market and assessing potential improvements and reforms; engagement with the wider financial services sector; and providing recommendations, including how any changes should be implemented by industry, regulators and government and what the appropriate timetable should be.

This is a key area of regulatory focus across the spectrum of different firms and markets. Due to the nature of the FX markets in particular and the reliance placed on them by a range of financial and non-financial institutions, the recent and ongoing developments in this space will impact both directly and indirectly on FX market participants. Two new operational resilience regimes are the EU Digital Operational Resilience Act (DORA) and the UK Critical Third Party (CTP) Regime. The CTP Regime came into force in the UK through the Financial Services and Markets Act 2023, and from 17 January 2025, EU Member States will be required to have national measures in place implementing the DORA directive.

There have been several recent global developments in the pre-hedging space. ESMA has published its findings following its call for evidence consultation of pre-hedging in 2023. The report discussed market views on the definition, scope and legitimacy of pre-hedging practice and set out provisional views on areas which could be covered in any future guidance. Further, the International Organisation of Securities Commissions (IOSCO) Q4 2023 survey covered similar points to the ESMA report and the Australian Securities and Investments Commission (ASIC) also published guidance on pre-hedging practices in February 2024.

Minute 4: Any other business

The Chair noted that George Johnston was stepping down as Secretary of FXJSC and introduced Sakshi Gupta, who is now joint-Head of the Central Banking Division in the Bank’s Legal Directorate (alongside James Brennan), as the new Secretary.


Sharon Blackman (Chair) – Citigroup

David Harris – Financial Conduct Authority (virtual)

Simon Goldsworthy – Deutsche Bank (virtual)

Gaynor Wood – CLS

Tamsin Rolls – JP Morgan Chase

Rakesh Shah – Standard Chartered (virtual)

Rowland Stacey – Goldman Sachs (virtual)

Harkamal Singh Atwal – HSBC (virtual)

Stephanie Cayer – Natwest (virtual)

Natalie Lovell – Bank of England (virtual)

FXJSC Legal Sub-Committee Secretariat

George Johnston (Secretary) – Bank of England

Sakshi Gupta – Bank of England

Matthew Hartley – Bank of England

Hana Mori – Bank of England

Charlotte Marshall – Bank of England

Guest attendees

Kate Sumpter – Allen & Overy

Louise Bralsford – Allen & Overy

Nick Bradbury – Allen & Overy (virtual)


Baljit Saini – NatWest Markets

Mayank Patel – Bank of America

Krisha Somaiya – UBS


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Minutes of the London FXJSC Main Committee Meeting – 6 March 2023

Time: 2pm – 4pm | Location: Hybrid – JP Morgan, 25 Bank Street, London, E14 5JP


Item 1 – Welcome and Apologies

Philippe Lintern (Chair, Bank of England) introduced Vicky Saporta as the new Executive Director of the Markets Directorate at the Bank of England. Mr Lintern also introduced Kate Hill (Aviva Investors), Sarah Collins (UBS Asset Management), Mani Natarajan (Morgan Stanley), and Jeremy Smart (XTX) as new members of the Committee.

Mr Lintern announced that George Johnston (Bank of England) had moved roles, and Sakshi Gupta would take over the Bank of England legal representation on the Committee. Mr Lintern thanked Mr Johnston for his contribution to the FXJSC and welcomed Ms Gupta to the Committee.

Mr Lintern welcomed Chris King (Dukes & King) and Tharidu Gamwara (JP Morgan) as observers.

Item 2 – November meeting Minutes, Terms of Reference Update & Diversity, Equity, and Inclusion (DE&I) action

The minutes of the 29 November 2023 meeting were approved.

The updated Terms of Reference were also approved. The updates introduced a two-year renewable membership term which would take effect from the beginning of 2025.

Mr Lintern asked Committee members to provide the Secretariat with contact details for DE&I leads at their respective firms to join a discussion on DE&I best practice.

Item 3 – FXJSC Turnover & FX Settlement Surveys

Natalie Lovell (Bank of England) gave a brief overview of the October 2023 FXJSC Turnover Survey results. Most of the results were in line with long-term survey trends. FX swaps remained the most traded instrument by turnover, at 46% of overall volume.

Ms Lovell explained that a new approach for collecting FX Settlement data had been trialled as part of the October 2023 FXJSC survey round.footnote [1] Following the trial, the Reporting Template and Guidelines had been updated to incorporate feedback from market participants and other central banks. Ms Lovell highlighted that the new approach would be adopted by two additional central banks for the April 2024 survey round, and also used by the Bank for International Settlements (BIS) as part of its 2025 Triennial Survey.

Item 4 – Market Update

Mimi Rushton (Barclays) and Rajesh Venkataramani (Goldman Sachs) presented an update on recent market developments.

The presenters noted that Federal Reserve monetary policy rate expectations had been the key driver of recent FX price action. Members discussed that FX positioning volumes had been low, driven by the market waiting for any divergence between central bank policy rate expectations.

Members discussed the drivers of the low FX volatility environment, including the current synchronisation between central bank monetary policy, and FX market efficiency gains over the last decade. Members discussed whether there had been a structural decline in volatility and the potential impact of the various 2024 elections.

Members noted the falling share of transactions going through primary venues as banks had internalised more FX trades. Members discussed whether the decline in primary venue volumes reflected a structural change in the market. Mr Lintern recalled the primary venues discussion at the September 2023 FXJSC meeting.

Item 5 – Update on FX Global Code review

Ms Lovell provided an update on the Global Foreign Exchange Committee’s (GFXC) priorities for 2024. Ms Lovell noted that there would be a targeted review of the FX Global Code, and areas of GFXC focus would include further mitigating FX settlement risk and enhancing FX data transparency. The Motivation for Adherence Working Group would also continue its outreach activities to increase awareness of the Code and its related materials, including the Disclosure Cover Sheets. The GFXC would also consider whether the Last Look and Pre-hedging guidance papers should be explicitly linked to the Code.

Item 6 – Evolution of custody FX services

Richard Purssell (Insight), Nina Moylett (M&G) and Sophie Rutherford (State Street) presented an overview on the evolution of custody FX services.

Mr Purssell explained that custody FX was an automated execution solution offered by custodians for security related FX and income repatriation activities. It was noted that although the asset owner was typically the custodian’s client, responsibility for custodian oversight would fall to the asset manager.

Mr Purssell highlighted that the level of data transparency around trade execution and the use of sub-custody services varied between custodians. As a result, some asset managers were moving back to managing FX in-house. Members noted that utilising custody FX reduced operational risk, especially for emerging market and restricted currencies.

Ms Moylett noted that there was limited data available on how much FX flow is managed by custodians in relation to the overall FX market. Members discussed the potential impact on the FX market should the custody FX model be disrupted and agreed it would be limited to a change in the way the transactions were executed.

Item 7 – FXJSC Sub-Committee updates

Sharon Blackman (Chair of the Legal Sub-Committee) noted the Sub-Committee had met on 5 March. Agenda items had included: an update on the FX Global Code review from Ms Lovell; and a review of recent UK and EU regulatory changes and their impact on the FX market from Allen & Overy LLP, including SA-CCR, accelerated securities settlement and the International Organization of Securities Commission’s (IOSCO) pre-hedging guidance.

James Kaye (Chair of the Operations Sub-Committee) noted the Sub-Committee had met on 28 February. Agenda items had included: accelerated securities settlement; an update on the FX Settlement Survey; the upcoming review of the FX settlement crisis playbook; ISO 20022; and a review of the potential operational impact of upcoming events.

Item 8 – Regular Updates

Alan Barnes (Financial Conduct Authority (FCA)) noted that the UK’s Accelerated Settlement Taskforce’s report examining the case for the UK moving to an accelerated securities settlement cycle would be published shortly.

Mr Barnes also noted that the FCA was reviewing comments on the responses received by IOSCO from regulatory authorities and market associations on its pre-hedging questionnaire. Mr Barnes added that IOSCO’s work could lead to strengthened pre-hedging standards, albeit leveraging existing market codes of conduct.

James Kemp (FMSB) noted work was underway by the Global Foreign Exchange Division (GFXD) to review existing guidance for resolving interest compensation claims. Mr Kemp also noted that a GFXD DE&I Next Step FX event would take place on 6 June 2024. The aim of the event would be to attract new talent to the FX industry.


Alan Barnes – Financial Conduct Authority

James Kaye (Chair, FXJSC Operations Sub-committee) – HSBC

James Kemp – FICC Markets Standards Board

Jeremy Smart – XTX Markets

Kate Hill – Aviva Investors

Lisa Dukes – Corporate Representative – Association of Corporate Treasurers

Mani Natarajan – Morgan Stanley

Marc Bayle de Jesse – CLS

Mimi Rushton – Barclays

Neehal Shah – BNP Paribas

Nina Moylett – M&G plc

Paul Houston – CME Group

Philippe Lintern (Chair) – Bank of England

Rajesh Venkataramani – Goldman Sachs

Richard Purssell – Insight Investment

Sally Francis-Cole – London Stock Exchange Group

Sarah Collins – UBS Asset Management

Sharon Blackman (Chair, Legal Sub-committee) – Citigroup

Sophie Rutherford – State Street

Stephen Jefferies – JP Morgan

Vicky Saporta – Bank of England

FXJSC Secretariat

George Johnston (Legal Secretariat) – Bank of England

Sakshi Gupta (Legal Secretariat) – Bank of England

Laura Austin – Bank of England

Natalie Lovell – Bank of England

Sita Mistry – Bank of England

Guest attendees

Chris King – Dukes & King

Tharidu Gamwara – JP Morgan


Galina Dimitrova – The Investment Association

Giles Page – Citigroup

Kevin Kimmel – Citadel Securities

Richard Bibbey – HSBC

Sarah Boyce – Association of Corporate Treasurers

Simon Manwaring – NatWest Markets


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Minutes of the London FXJSC Operations Sub-committee Meeting – 28 February 2024


Minute 1 – Welcome and Apologies

James Kaye (Chair, HSBC) introduced Gemma Webb Spooner (Bank of England), Louise Lee (Bank of England), Rachel Harding (Bank of England), and Rachel Stevens (Bank of England) as presenters. The Chair further noted that no observers had joined the meeting, and welcomed members to bring observers to the next meeting in June. The Chair also noted apologies from those unable to attend (listed at the end of the minutes).

Minute 2 – Minutes of the November Meeting and feedback from the November Main FXJSC Committee meeting

The minutes of the 22 November 2023 meeting were agreed by Committee members.

The Chair noted that the November Main Committee had been a shorter meeting due to the FXJSC 50th anniversary event. The main discussion topics had included key themes for FX markets going forward, risk mitigation solutions for currencies not covered by Payment versus Payment (PvP) providers, the potential impact of technological changes on FX intermediation, and a trend amongst asset managers to move back to managing FX in-house.

Minute 3 – Investment Association update

Alex Chow provided an update on Investment Association member firms’ preparations for the US move to T+1 securities settlement which was due to go-live on 28 May 2024. It was noted that some larger member firms had established US operations with a view to processing all FX transactions ahead of the 6pm EST CLS deadline for next-day settlement. Medium-sized members were planning to process as many FX transactions as possible ahead of the CLS deadline and use T0 settlement for any remaining FX transactions. Smaller members were exploring the use of FX custodians.

Mr Chow highlighted that the UK Accelerated Settlement Taskforce had progressed its thinking around accelerated securities settlement and was due to publish its report and recommendations within the next week. Mr Chow invited Committee members to join the UK Accelerated Settlement Taskforce’s FX technical group led by Andrew Harvey (Global Financial Markets Association (GFMA)).

Minute 4 – CLS update

John Hagon (CLS) provided updates on service levels, resilience, and T+1 securities settlement. Disruption to CLS settlement and funding had peaked in 2023, however there had only been one delay to settlement in 2024. Mr Hagon noted that CLS had been promoting uptake of CLSNet to help mitigate settlement risk associated with non-eligible CLS currencies, and that a significant buy-side firm was expected to adopt CLSNet within the next few months.

Mr Hagon noted that CLS had executed a successful market wide test of Member Replay at the end of 2023. As part of the test its 74 members had successfully demonstrated the ability to replay a set of Instructions (trades) in response to a data recovery scenario affecting CLSSettlement. Another test was planned for later this year, and it was noted that going forward these tests would be an annual occurrence.

Mr Hagon further noted that CLS continued to migrate to new and improved data centres for the CLSSettlement service with a target completion date of 2026. CLS was also working to introduce an alternative processing site by the end of 2024, subject to testing and relevant regulatory approvals.

Finally, Mr Hagon said that CLS had continued to review the results of its survey on the potential implications of the move to T+1 securities settlement on CLS cut-off times. He cited marked differences in member responses to the survey, and said that any changes to cut-off times were extremely unlikely ahead of US T+1 go-live at end-May.

Minute 5 – GFXD update

Steve Forrest (UBS) gave an overview of the most recent GFMA FX Operations Committee. He noted that ISDA had provided an update on planned changes to its ISDA Definitions. The move to T+1 securities settlement had also been discussed and the consensus view had been that if there was an additional demand for liquidity, then liquidity pools would adapt to accommodate that demand.

A working group has been established amongst certain members to discuss how best to improve velocity of interest claim resolution. It is also planned to consult with the International Securities Association for Institutional Trade Communication (ISITC) on the possibility of increasing the current $500 threshold for interest claims to $1000 in light of higher interest rates globally.

Finally, the June International Monetary Market (IMM) day was discussed. Mr Hagon noted that CLS was comfortable with the capacity of its systems to deal with the anticipated material increase in settlement volumes.

Minute 6 – FCA update

Oliver McCausland (FCA) noted that the FCA published a consultation in December last year on the transparency regime for bond and derivates markets (CP23/32). The purpose of the consultation was to improve the transparency regime in response to issues identified in the previous Wholesale Markets Review published on 01 March 2022. Mr McCausland further noted that the FCA was currently welcoming market participant views on the current level of transparency in FX derivatives markets.

Minute 7 – UK Finance update

Lorraine O’Donnell (UK Finance) noted that UK Finance had held a number of symposiums with critical FMI’s (CLS and CHAPS) and more recently with Amazon Web Services (AWS) to discuss resilience and impact tolerances. Ms O’Donnell also noted that there are plans to follow up with meetings between core firms and Financial Markets Infrastructure providers (FMIs), for example with CLS, to discuss impacts and timeframes against critical scenarios. Noting the SIMEX exercise (a sector resilience exercise) planned for later this year, firms have expressed strong appetite to proceed with a separate exercise that would fulfil their operational resilience testing requirements in the lead up to final implementation preparations. UK Finance plan to run an Operational Resilience Implementation Exercise (ORYX) in parallel to SIMEX, with proposed delivery date by end of H1 2024.

Minute 8 – FX settlement survey

Natalie Lovell and Matthew Conway (Bank of England) gave an update on the new approach to gathering FX settlement data which had been trialled as part of the October 2023 FXJSC survey round. It was noted that feedback from Reporting Dealers and other central banks had been used to inform updates to the Reporting Template and Guidelines ahead of the April 2024 reporting round. The structure of the Reporting Template remained unchanged, and updates to the Guidelines were aimed at improving clarity in certain areas, such as the treatment of back-to-back and compression trades.

Ms Lovell explained that it had been agreed at the November/December 2023 Global Foreign Exchange Committee (GFXC) meeting that, where possible and subject to readiness, central banks that already conduct, and co-ordinate semi-annual FX surveys would adopt the new approach for collecting FX settlement data for firms headquartered in their jurisdiction for the April 2024 round. Ms Lovell noted that the BIS would also adopt the new approach for the 2025 Triennial survey.

Minute 9 – 3-month forward event review

The Chair introduced a 3-month forward event review proposal as a way for Committee members to engage with and discuss events that could impact operations in FX markets, such as the upcoming Juneteenth IMM day. Members agreed with the proposal and the Secretariat agreed to take an action to consider how the forward planner would be updated and shared with Committee members.

Minute 10 – ISO20022 and the coexistence of MT settlement and MX payments

Rachel Stevens (Bank of England) presented on ISO 20022 and the coexistence of MT settlement and MX payments. Ms Stevens noted that from November 2025, MT 1, 2 and 9 series messages would be decommissioned by SWIFT and replaced by new ISO 20022 MX messages. The risk of confusion around terminology when confirming trade details was highlighted as one of the potential risks.

Joe Halberstadt (SWIFT) pointed Committee members to SWIFT’s standards documentation, and in particular SWIFT’s CBPR+ documentation which contains examples of specific payment scenarios including FX scenarios. Mr Halberstadt also noted that message usage guidelines for MT300 messages were being updated to reflect usage alongside MX payment messages.

Gavin Platman (Insight Investment) noted that small custodians would likely lag behind larger institutions in adopting MX messages for payments. The Chair noted that he would consult internally within HSBC and share any relevant feedback on the issues raised during the discussion.

Minute 11 – Any Other Business

Adam Dukes informed committee members that he would be stepping down from FXJSC Operations Sub-Committee. Committee members thanked Adam for his contribution to the Committee over the past seven years.


Aaron Mills – Citadel

Adam Jukes – Deutsche Bank

Alex Chow – Investment Association

Andrew Batchelor – LCH

Anna Chadderton – Goldman Sachs

Claire Forster-Lee – Morgan Stanley

Gavin Platman – Insight Investment

James Kaye (Chair) – HSBC

Joe Halberstadt – SWIFT

John Hagon – CLS

Oliver McCausland – FCA

Steve Forrest – UBS

FXJSC Secretariat

Hana Mori (Legal representative) – Bank of England

Joe Hearn – Bank of England

Natalie Lovell – Bank of England

Zish Jooma – Bank of England


Lorraine O’Donnell – UK Finance

Guest attendees

Gemma Spooner Webb – Bank of England (Presenter)

Louise Lee – Bank of England (Presenter)

Matthew Conway – Bank of England (Presenter)

Rachel Stevens – Bank of England (Presenter)


Andrew Grice – Bank of England

Andrew Rogan – UK Finance

Boyd Winston – JP Morgan

Fiona O’Riordan – Citi

Gail Smith (Deputy Chair) – RBC

Kerry Peacock (Deputy Chair) – MUFG

Mike Irwin – XTX Markets


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