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transforming global foreign exchange markets<br />

e-FOREX<br />

e-forex.net JANUARY <strong>2024</strong><br />

LOOK AHEAD<br />

Key e-FX developments we can<br />

expect in <strong>2024</strong><br />

T+1 SETTLEMENT<br />

What are the implications for FX?<br />

REGIONAL<br />

PERSPECTIVE<br />

Exploring the state of e-FX in<br />

Southern Africa<br />

NDFs<br />

The market looks towards<br />

increasing electronification<br />

DATA<br />

Putting it at the heart of FICC<br />

business strategy<br />

COVER INTERVIEW<br />

ANDREAS WIGSTRÖM<br />

MANAGING DIRECTOR OF LMAX GLOBAL<br />

LIQUIDITY • RISK MANAGEMENT • STP • E-COMMERCE


CitiVELOCITY<br />

COMMAND CENTRE<br />

• Visibility and control over user access and trading activity<br />

• Customisable alerts and bespoke reporting<br />

• NEW Export to Excel with SFTP for secure file transfer<br />

STILL INNOVATING<br />

Contact your eFX salesperson to learn more<br />

100+<br />

PLATFORM<br />

AWARDS<br />

12<br />

PATENTS<br />

$73 M<br />

© <strong>2024</strong> Citigroup Global Markets Inc. Member SIPC. All rights reserved. Citi Velocity, Citi Velocity & Arrow Design, Citi, Citi with Arc Design, Citigroup and CitiFX are<br />

service marks of Citigroup Inc. or its subsidiaries and are used and/or registered throughout the world. This product is offered through Citibank, N.A. which is authorised<br />

and regulated by the Financial Conduct Authority. Registered Office: Canada Square, Canary Wharf, London E14 5LB. FCA Registration number 124704. VAT Identification<br />

Number GB 429 625 629. Citi Velocity is protected by design and utility patents in the United States (9778821, 9477385, 8984439, D780,194, D780,194, D806,739) and<br />

Singapore (30201501598T, 11201505904S), and design registrations in the EU (0027845156-0001/0002, 002759266-0001).<br />

2 JANUARY <strong>2024</strong> e-FOREX


Welcome to<br />

e-FOREX<br />

transforming global foreign exchange markets<br />

<strong>January</strong> <strong>2024</strong><br />

We start this edition by reporting on the considerable progress that<br />

is being made regarding adherence to the FX Global Code. During its<br />

two-day virtual meeting held on 30th November - 1st December last<br />

year, the GFXC reported that during 2023, the GFXC Global Index of<br />

Public Registers reached 1,290 Statements of Commitment, an annual<br />

increase of 8% which represents significant progress in the uptake of<br />

the Code. It will be interesting to see the results of the 2023 FX Global<br />

Code Survey which are due to be released soon.<br />

Susan Rennie<br />

Susan.rennie@sjbmedia.net<br />

Managing Editor<br />

Charles Jago<br />

charles.jago@e-forex.net<br />

Editor (FX & Derivatives)<br />

Charles Harris<br />

Charles.harris@sjbmedia.net<br />

Advertising Manager<br />

Michael Best<br />

Michael.best@sjbmedia.net<br />

Subscriptions Manager<br />

David Fielder<br />

David.fielder@sjbmedia.net<br />

Digital Events<br />

Ingrid Weel<br />

mail@ingridweel.com<br />

Photography<br />

We next go on to explore the impact on FX markets of the imminent<br />

move to T+1 Securities Settlement. The reduction of the settlement<br />

cycle is likely to lead to additional complexities to post-trade processes<br />

and FX market participants are being encouraged to carefully analyse<br />

their operational and liquidity management practices to avoid<br />

disrupting market functioning.<br />

Our regular Look Ahead feature in this months <strong>January</strong> edition<br />

focuses attention on some of the key developments in e-FX we are<br />

likely to see this year and our Regional Perspective report looks at the<br />

continued expansion of electronic FX trading in Southern Africa and<br />

the prospects for its growth across both East and West Africa over the<br />

next few years.<br />

The advantages of putting data at the heart of FICC business strategy is<br />

what we are talking about in our data management article. This sounds<br />

relatively easy but it isn’t. Trading firms may have systems in place to<br />

capture data, but to use it in a consistent and repetitive process at the<br />

performance levels they need is a complex and expensive undertaking.<br />

Relying on specialist providers to overcome the challenges and take<br />

some of the pain away is one way of tackling the issues so we talk to a<br />

few to discover what solutions they have on offer.<br />

Finally our Special Report in this edition looks at why demand for NDFs<br />

continue to surge and the role of electronic trading and associated<br />

technology to help meet this. The future prospects for NDFs look good<br />

for a variety of reasons including the growth of various emerging<br />

market economies. As asset managers continue to increase their asset<br />

allocation in these respective markets, usage of NDFs as a hedging tool<br />

will increase. In response, the electronic trading capabilities of NDFs,<br />

including the usage of NDF algos, will continue to evolve as well.<br />

Ben Ezra<br />

Ben.ezra@sjbmedia.net<br />

Retail FX Consultant<br />

Tim Hendy<br />

tim@thstudio.co.uk<br />

Web Manager<br />

SJB Media International Ltd<br />

Suite 153, 3 Edgar Buildings, George Street,<br />

Bath, BA1 2FJ United Kingdom<br />

Tel: +44 (0) 1736 74 01 30 (Switchboard)<br />

Tel: +44 (0) 1736 74 11 44 (e-<strong>Forex</strong> editorial & sales)<br />

Fax: +44 (0)1208 82 18 03<br />

Design and Origination:<br />

Matt Sanwell, DesignUNLTD<br />

www.designunltd.co.uk<br />

Printed by Headland Printers<br />

e-<strong>Forex</strong> (ISSN 1472-3875) is published monthly<br />

www.e-forex.net<br />

Membership enquiries<br />

Access to the e-<strong>Forex</strong> website is free to all registered<br />

members. More information about how to register<br />

can be found at www.e-forex.net<br />

To order hard copies of the publication<br />

or for more information about membership<br />

please call our subscription department.<br />

Members hotline: +44 (0)1736 74 01 30<br />

Although every effort has been made to ensure the accuracy of the information<br />

contained in this publication the publishers can accept no liabilities for<br />

inaccuracies that may appear. The views expressed in this publication are not<br />

necessarily those of the publisher.<br />

Please note, the publishers do not endorse or recommend any specific website<br />

featured in this magazine. Readers are advised to check carefully that any<br />

website offering a specific FX trading product and service complies with all<br />

required regulatory conditions and obligations.<br />

The entire contents of e-<strong>Forex</strong> are protected by copyright and all rights are<br />

reserved.<br />

As usual I hope you enjoy reading this edition of the magazine.<br />

Charles Jago, Editor<br />

JANUARY <strong>2024</strong> e-FOREX 3


<strong>January</strong> <strong>2024</strong><br />

CONTENTS<br />

REGULATORY<br />

ISSUES<br />

14. FX measures the impact<br />

of the latest FX Global Code<br />

review and imminent move<br />

towards T+1 settlement<br />

Vivek Shankar investigates in what<br />

ways the FX Global Code’s influence<br />

is set to increase further and what<br />

are the implications for FX as U.S.<br />

securities move to T+1 settlement.<br />

We asked Chris Gibson, Director<br />

of Payments at smartTrade<br />

Technologies, to tell us more<br />

about his firm’s new classleading<br />

FX and payments<br />

platform.<br />

E-FOREX INTERVIEW<br />

38. With Andreas Wigström,<br />

Managing Director, LMAX<br />

Global<br />

CONTENTS<br />

Nicholas Pratt<br />

Look Ahead<br />

Matt Kassel<br />

Product Launch<br />

Marc Bayle de Jessé<br />

Growth of CLSNet<br />

Vivek Shankar<br />

Regulatory Developments<br />

Andreas Wigström<br />

e-<strong>Forex</strong> Interview<br />

Chris Gibson<br />

CBP Platform<br />

MARKET<br />

COMMENTARY<br />

22. A Look Ahead at what we<br />

can expect with e-FX in <strong>2024</strong><br />

Nicholas Pratt explores some of the<br />

key developments in electronic FX<br />

that are likely to take place this year.<br />

PROVIDER<br />

VIEWPOINT<br />

26. The growth of CLSNet:<br />

The next best thing after<br />

CLSSettlement<br />

By Marc Bayle de Jessé, CEO of<br />

CLS.<br />

REGIONAL E-FX<br />

PERSPECTIVE<br />

28. Exploring the state of<br />

e-FX and associated fintech in<br />

Southern Africa<br />

Vivek Shankar discovers that<br />

electronification in FX is increasing<br />

not just in South Africa but across<br />

the whole continent.<br />

PRODUCT REVIEW<br />

36. CBP: A versatile and<br />

powerful platform to deliver FX<br />

and payments solutions<br />

SPECIAL REPORT<br />

46. NDFs: The market<br />

looks towards increasing<br />

electronification to meet rising<br />

demand<br />

As the demand for NDFs continue<br />

to surge, Nicholas Pratt examines<br />

the role of electronic trading and<br />

technology to meet this.<br />

EXPERT OPINION<br />

58. The value of performance<br />

analysis and network<br />

monitoring solutions to the<br />

trading world<br />

Beeks Group outlines how a costly<br />

IPO sparked the genesis of Market<br />

Data Capture and Replay solution<br />

mdPlay.<br />

DATA MANAGEMENT<br />

60. Putting data at the heart of<br />

FICC business strategy<br />

Vivek Shankar finds out more<br />

about the challenges that FX<br />

trading firms are facing when<br />

managing and exploiting their data<br />

and the technology solutions that<br />

are now becoming available to<br />

address these.<br />

COMPANIES IN THIS ISSUE<br />

A<br />

Alp Financial<br />

B<br />

Beeks<br />

Bloomberg<br />

C<br />

Centroid Solutions<br />

Citi<br />

CLS<br />

p52<br />

p58<br />

p49<br />

p65<br />

IFC<br />

p17<br />

E<br />

Edgewater Markets<br />

Euronext<br />

F<br />

Factset<br />

FairXchange<br />

Finalto<br />

Flextrade<br />

FXSpotStream<br />

p12<br />

p57<br />

p21<br />

p6<br />

p55<br />

p8<br />

p9<br />

L<br />

LMAX Global<br />

Loop FX<br />

LSEG<br />

M<br />

Mosaic Smart Data<br />

O<br />

oneZero<br />

p38<br />

p8<br />

p16<br />

p61<br />

p63<br />

R<br />

Rand Merchant Bank<br />

Refinitiv<br />

S<br />

Saxo Bank<br />

smartTrade Technologies<br />

Swissquote Bank<br />

T<br />

360T<br />

Tradefeedr<br />

p33<br />

p31<br />

p5<br />

p19<br />

p7<br />

p30<br />

p61<br />

D<br />

DMALINK<br />

p10<br />

I<br />

IPC<br />

OBC<br />

P<br />

PLUGIT<br />

IBC<br />

W<br />

WBR<br />

p53<br />

4 JANUARY <strong>2024</strong> e-FOREX


FX prime<br />

brokerage<br />

Customised FX & precious metal<br />

liquidity and clearing solutions<br />

With Saxo’s technology-driven prime brokerage services partners access<br />

top tier bank and non-bank liquidity providers and venues.<br />

Our FX prime brokerage combines co-located connectivity in all three major<br />

liquidity centres, credit intermediation, ultra-low latency pre-trade credit risk<br />

controls, bespoke pricing and execution analytics.<br />

Saxo caters to clients of all sizes, from those who are too small to access<br />

the services of major investment bank prime brokers, to large clients who<br />

choose Saxo due to the quality of our service and offerings.<br />

Our partners benefit from the trust and security of a regulated and licensed<br />

Danish bank with a global footprint, authorised in multiple jurisdictions.<br />

31% 13.1% 272%<br />

Total capital ratio ICAAP requirement Liquidity coverage ratio<br />

SIFI<br />

Designated Systemically<br />

Important Financial Institution<br />

by Danish FSA<br />

BBB<br />

S&P Global Ratings<br />

Learn more at www.institutional.saxo<br />

Contact: solutions-uk@saxomarkets.com<br />

+44 207 151 2100<br />

This material is produced for marketing purposes only. Trading in financial instruments carries<br />

some degree of risk, always ensure you fully understand all the risks before trading.<br />

Read Saxo’s full disclaimer at www.home.saxo/legal/disclaimer/saxo-disclaimer.<br />

JANUARY <strong>2024</strong> e-FOREX 5


Wells Fargo joins FXSpotStream<br />

FXSpotStream LLC has announced that exciting to see this level of interest<br />

Wells Fargo has joined FXSpotStream in becoming a liquidity provider<br />

and is now live with multiple<br />

on the Service. FXSpotStream has<br />

clients, becoming the 16th bank become a name synonymous with<br />

connected to FXSpotStream’s price<br />

streaming service, joining Bank of<br />

America, Barclays, BNP Paribas, Citi,<br />

Commerzbank, Goldman Sachs, HSBC,<br />

J.P.Morgan, Morgan Stanley, MUFG,<br />

NatWest, Standard Chartered, State<br />

Street, Societe Generale and UBS.<br />

FXSpotStream CTO, Tom San Pietro<br />

commented: “It is tremendously<br />

Tom San Pietro<br />

growth, client service, performance<br />

and reliability. We feel that these<br />

qualities are what have made us such<br />

an appealing prospect for LPs. We are<br />

extremely excited to be working with<br />

Wells Fargo and adding another highquality<br />

liquidity provider that had<br />

been requested by our client base. In<br />

Q4 of last year, we added our first LP<br />

since 2020 and having a second now<br />

live is confirmation that the plans that<br />

we created with the goal of adding<br />

additional LPs have been effective and<br />

are delivering the desired results.”<br />

Saxo Bank partners with FairXchange<br />

NEWS<br />

Saxo Bank has become the latest<br />

institution to join the rapidly growing<br />

FairXchange ecosystem. Under the<br />

terms of the arrangement FairXchange<br />

are providing their award-winning<br />

liquidity management platform Horizon.<br />

Guy Hopkins, CEO and Founder of<br />

FairXchange said “We are delighted<br />

to welcome Saxo to the FairXchange<br />

network. They were one of the very<br />

first institutions to embrace datadriven<br />

dialogue with their Liquidity<br />

Providers, and they have always had a<br />

deep understanding of the importance<br />

of working with their LPs to source the<br />

best possible liquidity. We are delighted<br />

to help them continue in that spirit of<br />

Guy Hopkins<br />

collaboration, working with them to<br />

help them maximise opportunities for<br />

them, their LPs and their clients.”<br />

James Dewdney-Herbert at Saxo<br />

commented “The relationship with<br />

FairXchange is already off to a very<br />

strong start. Since we went live with<br />

FairXchange we have already noted a<br />

material uplift in engagement from our<br />

trusted liquidity partners, leading to<br />

greater profitability both for them and<br />

for us, ultimately resulting in better<br />

liquidity for our clients.”<br />

Finalto Asia partners with PrimeXM<br />

Finalto Asia and PrimeXM have<br />

with PrimeXM, leveraging our XCore<br />

announced a strategic partnership technology at the Equinix SG1 data<br />

which aims to reshape the FX and CFD center, marks a significant milestone<br />

landscape in Asia and firmly establish for our growth in the APAC region. This<br />

exciting new liquidity solutions in<br />

initiative underscores our commitment<br />

the region through collaboration.<br />

to delivering sophisticated and efficient<br />

By combining the financial service<br />

experience of Finalto Asia and the cuttingedge<br />

technology expertise of PrimeXM,<br />

a leading technology provider for the<br />

finance industry, the two are better<br />

prepared than ever to establish robust<br />

and sophisticated liquidity frameworks.<br />

Clive Diethelm, PrimeXM Founder<br />

Alex Mackinnon<br />

stated: “Finalto Asia’s collaboration<br />

trading technology solutions, enhancing<br />

our service offering in Singapore’s<br />

dynamic financial market.” Meanwhile<br />

Alex MacKinnon, Regional CEO of Finalto<br />

Asia, also expressed enthusiasm about the<br />

partnership, stating: “This collaboration<br />

with PrimeXM is a strategic milestone<br />

for Finalto Asia. By combining our<br />

strengths, we aim to deliver unparalleled<br />

liquidity solutions and advanced trading<br />

technologies to the financial community<br />

in Singapore and the region.” By working<br />

together, Finalto Asia and PrimeXM will<br />

be able to seamlessly aggregate liquidity<br />

from various source<br />

6 JANUARY <strong>2024</strong> e-FOREX


Institutional<br />

EMBARK POWERFUL<br />

LIQUIDITY SOLUTIONS<br />

Combine power and tailor-made for best-in-class execution on FX Spot, Metals,<br />

Swaps, Forwards and Commodities. With a deep liquidity pool, custom streams,<br />

a hybrid execution model and the best trading environments, you are ready to<br />

expand your counterparty network.<br />

Partner with the Swiss leader in online banking (SIX:SQN).<br />

swissquote.com/fx-prime<br />

JANUARY <strong>2024</strong> e-FOREX 7


FlexTrade and LSEG collaborate<br />

FlexTrade Systems has announced a<br />

partnership to deliver FlexTRADER EMS<br />

clients seamless access to FXall, LSEG’s<br />

leading electronic trading platform<br />

for global currency products. The<br />

partnership will enable new mutual<br />

clients access to FXall execution services<br />

from within the FlexFX EMS. Through<br />

the delivery of the highly customizable<br />

FlexFX front end, clients trading FX will<br />

be able to access FXall’s extensive global<br />

liquidity network, including support<br />

for spots, forwards, swaps, NDFs, and<br />

options, which can be executed on<br />

FXall’s regulated environments such as<br />

MTF and SEF. Further, FXall’s liquidity can<br />

be combined with FlexTrade’s liquidity<br />

and automation capabilities, including<br />

FlexAlgoWheel, to streamline lowtouch<br />

FX orders.Jill Sigelbaum, Head of<br />

Strategic Development & Partnerships,<br />

FX, at LSEG, noted: “We are delighted<br />

to join forces with FlexTrade to provide<br />

clients with an enhanced multi-asset<br />

offering. Our priority at LSEG is to<br />

understand our clients’ FX needs and<br />

meet them where they want to trade.<br />

By combining FlexTrade’s customizable<br />

interface with FXall’s world-class,<br />

regulated liquidity pools, the offering<br />

provides the strongest end-to-end<br />

solution in the market today.”<br />

Jill Sigelbaum<br />

Central Bank of Kenya launches Bloomberg’s Bmatch solution<br />

NEWS<br />

The Central Bank of Kenya has<br />

announced the launch of Bloomberg’s<br />

BMatch solution for interbank<br />

trading in the local foreign exchange<br />

market. BMatch offers spot matching<br />

functionality to the interbank<br />

community for US Dollar against<br />

the Kenyan Shilling. BMatch allows<br />

anonymous orders to be placed into<br />

a central limit order book, which are<br />

displayed and then matched with<br />

counterparty orders based on mutual<br />

trading limits and other parameters<br />

configured by each bank. The solution<br />

can be integrated with banks’ middle<br />

and back-office systems. Consolidated<br />

trade statistics can also be calculated<br />

Tod Van Name<br />

and made available to the market.<br />

“We are delighted to support the<br />

Central Bank of Kenya with our BMatch<br />

solution, which will help increase<br />

transparency, liquidity and efficiency<br />

on the local foreign exchange market.<br />

Bloomberg has extensive experience in<br />

providing robust technical infrastructure<br />

solutions for foreign exchange markets<br />

and can easily adapt these to the<br />

specific needs of any market around the<br />

world,” said Tod Van Name, Bloomberg’s<br />

Global Head of FX Electronic Trading.<br />

LoopFX to be integrated into FactSet’s Portware<br />

trading platform<br />

LoopFX and FactSet have announced<br />

plans to integrate LoopFX into FactSet’s<br />

FX execution management system,<br />

Portware, in early <strong>2024</strong>. Renowned<br />

for its market-leading data, analytics,<br />

and innovative technology solutions,<br />

FactSet will embed LoopFX’s groundbreaking<br />

‘Peer-To-Bank’ matching engine<br />

technology into Portware, providing<br />

FactSet’s clients easy access within<br />

their existing workflows directly on<br />

their trading screen. FactSet’s Portware<br />

Platform is an advanced multi-asset<br />

Execution Management System (EMS)<br />

used by leading buy-side traders<br />

worldwide. Portware enables traders<br />

to analyze, communicate, and execute<br />

orders with diverse market participants<br />

and liquidity destinations through<br />

highly efficient, customized, and<br />

automated workflows. “We are pleased<br />

to announce the integration of LoopFX<br />

into FactSet’s Portware Platform,” said<br />

Chris Matsko, Head of Foreign Exchange<br />

Trading Services at FactSet. “This<br />

announcement showcases FactSet’s<br />

dedication to enhancing our products<br />

by working with innovative solutions<br />

that provide the best possible outcomes<br />

to our valued clients.” Blair Hawthorne,<br />

Founder and CEO of LoopFX, says, “We<br />

are delighted to partner with another<br />

global award-winning FX industryleading<br />

platform. Portware is a trusted<br />

hub for some of the world’s largest asset<br />

managers whose clients now have direct<br />

access to LoopFX functionality within<br />

their preferred workflows.”<br />

Chris Matsko<br />

8 JANUARY <strong>2024</strong> e-FOREX


Evolving with the Market<br />

Added Functionality to Support Algos & Allocations Now Live<br />

®<br />

GUI<br />

Live<br />

RFS<br />

Functionality<br />

Added<br />

London<br />

& Tokyo<br />

Offices Open<br />

FX|Insights<br />

Analytics Tool<br />

Launched<br />

USD11T<br />

Supported<br />

for 2020<br />

FX Spot<br />

Streaming<br />

Only<br />

FX Fwds,<br />

Swaps Added<br />

Streaming<br />

Precious<br />

Metals Added<br />

NDF/NDS,<br />

PM Swaps<br />

Added<br />

Total Reaches<br />

15 LPs<br />

Algos &<br />

Allocations<br />

Functionality<br />

Added<br />

®<br />

FXSpotStream is a bank owned consortium operating as a market utility, providing the infrastructure<br />

that facilitates a multibank API and GUI to route trades from clients to LPs. FXSpotStream provides a<br />

multibank FX streaming Service supporting trading in FX Spot, Forwards, Swaps, NDF/NDS and<br />

Precious Metals Spot and Swaps. Clients access a GUI or single API from co-location sites in New York,<br />

London and Tokyo and can communicate with all LPs connected to the FSS Service. Clients can also<br />

access the entire Algo Suite of the FSS LPs, and assign pre- and/or post-trade allocations to their<br />

orders. FXSpotStream does not charge brokerage fees to its clients or LPs for its streaming offering.<br />

Algo fees from an LP are solely determined by the LP.<br />

JANUARY <strong>2024</strong> e-FOREX 9


Commerzbank goes live<br />

with DMALINK<br />

We ask Michael Siwek, Founder/CRO of DMALINK to tell us more about<br />

this important partnership with Commerzbank, who will now stream prices<br />

electronically onto the firms platform.<br />

NEWS STORY<br />

Commerzbank being an organisation<br />

that is not afraid to take the lead<br />

and press forward with the evolving<br />

global financial market. Recent<br />

press announcements made by<br />

Commerzbank signify a huge shift<br />

in the direction of the digital asset<br />

industry and bank involvement. On a<br />

related note, DMALINK has launched<br />

its own digital asset venue which<br />

is catering to large, regulated, FIs.<br />

This to us, signifies a large move<br />

in the market towards institutional<br />

adoption of digital assets and digital<br />

asset trading.<br />

What sort of criteria do you look<br />

at before you invite a market<br />

maker to join your ecosystem?<br />

Michael Siwek<br />

Why has this strategic<br />

collaboration arrived at a<br />

very opportune moment for<br />

DMALINK?<br />

DMALINK, since its inception, has<br />

been searching for innovative FX<br />

solutions outside status quo. We’ve<br />

adopted a different pricing model<br />

by not charging LPs, a different<br />

approach to clients and LPs alike,<br />

yielding long-lasting relationships.<br />

Commerzbank is regarded as one<br />

of the most established German<br />

banks, a highly regulated, in a fastpaced<br />

and functioning environment<br />

where the ‘entrepreneurial’ spirit<br />

is alive and well. Many large banks<br />

write about innovation, digitization<br />

and the likes, hiring teams that<br />

end up dissolving in a matter of<br />

months due to lack of direction,<br />

albeit, enormous budgets spent<br />

on the endeavour. What we see in<br />

Great question. The criteria are<br />

dictated by the clients who use our<br />

venue for their trade execution,<br />

settlement and post-trade execution<br />

analysis. Different clients have<br />

differing types of flow, whereas<br />

many banks will be directional,<br />

as will be the pension funds, it is<br />

likely that hedge fund clients will<br />

be taking a different view to the<br />

market. This means, we must have a<br />

diversity of liquidity on the platform.<br />

We look at the currencies most<br />

traded on the platform, and find<br />

LPs which excel in that space. From<br />

there, we’ll look at the sizes they are<br />

comfortable with and match that<br />

to the sizes we see going through<br />

10 JANUARY <strong>2024</strong> e-FOREX


NEWS STORY<br />

our systems in LD and NY. Then,<br />

we must look at the timeframes<br />

with which the banks work when<br />

internalising positions and compare<br />

that to the data we see coming<br />

from the client’s data pool to see<br />

whether that matches. Lastly, our<br />

team play a pivotal role here in<br />

matching the data, the sizes, the<br />

currencies, to the appropriate LPs.<br />

From there, we start a 4–6-week<br />

process of a collaborative approach<br />

between us, the client and the LP<br />

whereby we have weekly calls to<br />

assess the performance on both<br />

sides of the equation. During this<br />

time, we often make adjustments<br />

driven by the data, our sales and<br />

data teams will jointly speak<br />

with the LPs and clients to better<br />

understand the flow and pricing<br />

and make changes. I wish I could<br />

say it’s an easier process but, it<br />

takes time and effort to create a<br />

working ecosystem, especially, in a<br />

market where flow and pricing alike<br />

changes from time to time.<br />

How will the addition of<br />

Commerzbank help you to meet<br />

your core FX liquidity objectives?<br />

We see a significant demand in<br />

CEE currencies aside the G5 that’s<br />

market-dominant in terms of<br />

volume. Our clients see value in<br />

trading these pairs given there’s a<br />

larger potential for profit as margins<br />

are still larger than those of the<br />

G5. We were looking forward to<br />

working with the FX desk and<br />

the broader Commerzbank team<br />

to ensure we can provide our<br />

clients with great pricing, allowing<br />

them to trade more by driving<br />

more strategies towards these<br />

pairs. Commerzbank has a huge<br />

franchise business of corporates<br />

and retail clients whereby both can<br />

lean heavily on their FX expertise,<br />

from local businesses to large<br />

multinationals.<br />

Amidst its expanding asset<br />

classes, DMALINK remains<br />

dedicated to embedding FX<br />

within its electronic trading<br />

platforms. Why is that and<br />

what makes your ECN model<br />

increasingly attractive for many<br />

trading firms?<br />

DMALINK is uniquely positioned<br />

within the FX space by delivering<br />

multiple touchpoints to our<br />

clients. As we entered the digital<br />

asset space, we understand that<br />

Deliverable FX, settled in a timely<br />

manner is still a pain point for<br />

many firms. Given our market-wide<br />

connectivity to many bank and nonbank<br />

LPs we can provide wholesale<br />

prices to the digital asset space<br />

with same-day delivery (T+0) on<br />

large orders. This gives LPs access to<br />

flow based on client transactions as<br />

opposed to trading strategies.<br />

A major theme throughout<br />

this edition of e-<strong>Forex</strong> is the<br />

importance of putting data<br />

at the heart of FICC business<br />

strategy. DMALINK is well known<br />

as a data-centric ECN. What<br />

does that mean in practice and<br />

what benefits does it deliver for<br />

clients?<br />

Absolutely right, we’ve done away<br />

with manually intense processes in<br />

favour of machine learning and AIdriven<br />

liquidity management to help<br />

us make much faster decisions on the<br />

ever-changing structure of the flow<br />

and how it interacts with our LPs.<br />

This enables us to react far quicker<br />

than previously possible, and, helps us<br />

maximize the LP yield while minimizing<br />

the market impact.<br />

This month we are also exploring<br />

the move to T+1 Settlement later<br />

this year and the potential impact<br />

this will have on FX. What are your<br />

own thoughts about?<br />

Improving settlement-times<br />

in FX is critical from a capital<br />

allocation and credit perspective.<br />

It further reduces counterparty risk<br />

considerations.<br />

We currently provide T+0 settlement<br />

when clients buy or sell fiat<br />

currencies against crypto currency<br />

such as Bitcoin, Stable Coins or<br />

Ethereum. This type of bridge<br />

between TradFi and DeFi enables<br />

clients prompt access to capital and<br />

reduces the burden of overallocation<br />

of credit.<br />

What plans do you have this<br />

year for enhancing DMALINK’s<br />

and Definity’s product offering<br />

further and growing its business<br />

footprint globally?<br />

As DMALINK continues to grow<br />

organically, we dive deeper into<br />

solving the intricate issues found in<br />

the digital asset space by listening<br />

to the regulated institutions we all<br />

know from the world of FX.<br />

One of the projects we launched<br />

recently is our Deliverable T+0 FX for<br />

DeFi. This is a move driven by client<br />

demand and necessity as the market<br />

continues to struggle with the FX<br />

component of the transactions,<br />

simultaneously as the market<br />

matures and expects things to be<br />

done at a much quicker rate. Fiat<br />

on/off continues to be a struggle for<br />

many companies.<br />

Applying institutional FX methods<br />

from a pre and post trade<br />

perspective and considering<br />

counterparty risk metrics,<br />

and settlement and PB credit<br />

intermediation systems we are<br />

currently introducing new trading<br />

and operational efficiencies into the<br />

digital assets landscape to make<br />

crypto trading faster, cost efficient,<br />

secure and stable.<br />

JANUARY <strong>2024</strong> e-FOREX 11


EDGE FX RFQ:<br />

Profiling the groundbreaking<br />

new RFQ solution from<br />

Edgewater Markets<br />

PRODUCT LAUNCH<br />

We asked Matt Kassel, Chief Operating Officer at the firm to tell us more<br />

about its exciting new trade execution service.<br />

Matt Kassel<br />

What prompted Edgewater<br />

Markets to design and launch this<br />

new Request for Quote (RFQ) trade<br />

execution service?<br />

Edgewater Markets designed and<br />

launched the new Request for Quote<br />

(RFQ) trade execution service in<br />

response to strong client demand<br />

and as a natural extension of their<br />

leading NDF and Spot streaming<br />

services. Clients value the anonymity,<br />

credit intermediation, and access<br />

to deep local liquidity that this<br />

offering provides through a single<br />

connection, while effectively reducing<br />

market impact. With evolving market<br />

dynamics and changing client<br />

preferences, there is a growing need<br />

for more versatile and innovative<br />

ways to trade, especially for less liquid<br />

instruments like NDF and NDS. While<br />

our streaming service is efficient<br />

for standardized trade sizes, clients<br />

increasingly expressed the need for<br />

executing larger trade sizes with local<br />

providers who specialize and can easily<br />

accommodate large transaction sizes in<br />

their local currency. The introduction<br />

of RFQ trade execution was Edgewater<br />

Markets’ response to this demand,<br />

providing clients the flexibility required<br />

to efficiently manage order flow of any<br />

size or value date.<br />

Why is EDGE FX RFQ so<br />

transformational for the FX trading<br />

market?<br />

EDGE FX RFQ service represents a<br />

transformational shift in how the<br />

Global FX market transacts for several<br />

compelling reasons. Firstly, it challenges<br />

and disrupts traditional trading<br />

methods that heavily rely on voice and<br />

chat interactions. By automating the<br />

workflow, EDGE FX RFQ allows local<br />

liquidity providers to scale their business<br />

and extend their reach, enhancing<br />

overall global market efficiency.<br />

In addition, the service is the first<br />

of its kind to provide anonymous<br />

RFQ trading coupled with credit<br />

intermediation. This unique feature not<br />

only ensures that market participants<br />

can execute trades with enhanced<br />

privacy, but it also simplifies access to<br />

deep local providers who specialize<br />

in their currency. This innovation is a<br />

game-changer, allowing traders to<br />

effectively manage their positions,<br />

while providing access to a wide array<br />

of local liquidity sources through a<br />

single platform.<br />

What customization of orders is<br />

possible with EDGE FX RFQ?<br />

EDGE FX RFQ offers a remarkable<br />

degree of order customization,<br />

12 JANUARY <strong>2024</strong> e-FOREX


PRODUCT LAUNCH<br />

granting users full control over the<br />

execution of their trading strategies.<br />

Users can opt for one-sided or twoway<br />

orders, tailoring their orders<br />

to specific market conditions and<br />

individual preferences. Additionally,<br />

the platform accommodates the<br />

trading of broken dates and swaps<br />

across FX metals and NDFs. This level<br />

of customization empowers traders<br />

to engage the market directly for<br />

large size orders resulting in a single<br />

trade and counterpart, enhancing<br />

their ability to navigate the FX market<br />

effectively and efficiently.<br />

What other key features does<br />

EDGE FX RFQ incorporate?<br />

EDGE FX RFQ incorporates a<br />

unique set of features to optimize<br />

the foreign exchange trading<br />

experience. Notably, the platform<br />

facilitates the aggregation of the<br />

best bids and offers from multiple<br />

local providers via a single credit<br />

line, fostering competitive rates and<br />

streamlined trading. The inclusion<br />

of credit intermediation is pivotal,<br />

removing the need to establish direct<br />

credit relationships with multiple<br />

local market participants in each<br />

country, thus broadening market<br />

participation. Additionally, the<br />

platform embraces Straight-Through<br />

Processing (STP), automation and<br />

audit functions, ensuring seamless<br />

and error-free best execution, while<br />

aligning with emerging market<br />

shift toward electronic transaction<br />

processes. This integrated approach<br />

enhances overall efficiency, price<br />

discovery, and risk management in<br />

the FX market.<br />

What direct benefits will it deliver<br />

to your clients?<br />

EDGE FX RFQ delivers direct benefits<br />

to global clients and local liquidity<br />

providers, driven by the platform’s<br />

capacity to aggregate pricing from<br />

multiple local sources anonymously.<br />

This heightened liquidity access<br />

attracts global market participants,<br />

resulting in a more robust market,<br />

by providing a wider array of trading<br />

opportunities. Additionally, clients<br />

experience a tangible improvement<br />

in trade execution through narrowed<br />

spreads and reduced slippage,<br />

especially in the handling of larger<br />

orders, by directing each trade to<br />

specific providers who specialize in<br />

the pair size and tenor. The platform’s<br />

automation ultimately leads to cost<br />

savings and enhanced profitability for<br />

both clients and LPs.<br />

Edgewater Markets has a long<br />

history of driving innovation in<br />

FX trading. How excited are you<br />

about the positive impact EDGE<br />

FX RFQ will have and the new<br />

trading strategy possibilities it<br />

will open up?<br />

Edgewater Markets has a rich<br />

history of pioneering innovation in<br />

FX trading, and we are incredibly<br />

excited about the positive impact<br />

that EDGE FX RFQ is delivering.<br />

This groundbreaking functionality<br />

is the first of its kind, setting a<br />

new standard in the industry,<br />

revolutionizing the way FX trades are<br />

executed.<br />

One of the most exciting aspects<br />

of EDGE FX RFQ is that clients<br />

are embracing and advancing<br />

their trading strategies by using<br />

algorithms within the platform. This<br />

demonstrates the immediate value<br />

and adaptability of this cutting-edge<br />

solution, as clients find innovative<br />

ways to optimize their trading<br />

operations to achieve superior results.<br />

Looking ahead, we are enthusiastic<br />

about the prospects of extending<br />

EDGE FX RFQ to a broader client<br />

base and encouraging more buyside<br />

participation. This expansion<br />

promises to open new avenues for<br />

traders, allowing them to explore<br />

diverse trading strategies and choice<br />

in execution methodology that<br />

capitalize on the unique features<br />

and benefits offered by the platform.<br />

We believe that this groundbreaking<br />

development and access to deep local<br />

liquidity in an anonymous fashion will<br />

reshape the FX trading landscape and<br />

empower clients to take their trading<br />

to new heights.<br />

JANUARY <strong>2024</strong> e-FOREX 13


FX measures the impact of<br />

the latest FX Global Code<br />

review and imminent move<br />

towards T+1 settlement<br />

By Vivek Shankar<br />

REGULATORY ISSUES<br />

The Global Foreign Exchange Committee (GFXC) and<br />

its Code have played an integral part in standardising<br />

FX market practices. Adopting the Code’s 55 principles<br />

is voluntary and has prompted significant cooperation<br />

between private and public sectors. The latest of the GFXC’s<br />

periodic reviews closed late last year, with the results<br />

due for publishing in <strong>January</strong> <strong>2024</strong>. What are some of the<br />

concerns in this latest iteration, and will Code changes<br />

address the T+1 elephant in the room?<br />

Image by Shutterstock<br />

14 JANUARY <strong>2024</strong> e-FOREX


REGULATORY ISSUES<br />

A BRIEF OVERVIEW OF CODE<br />

ADOPTION<br />

“In the six years since it was<br />

established, the Code has expanded<br />

its reach across the FX industry,” Anna<br />

Nordstrom, Head of the Domestic and<br />

International Markets Functions at the<br />

New York Federal Reserve Bank (The<br />

Fed,) said in October last year at FX<br />

Markets USA.<br />

She explained that over 1,000<br />

market participants worldwide have<br />

adopted the Code, with the adopters’<br />

nature changing. “Whereas the<br />

initial adopters were bank dealers,<br />

platforms, and technology providers,<br />

we have seen greater adoption by the<br />

asset management community more<br />

recently,” she said.<br />

Currently, 11 of the top 15 asset<br />

management firms in the US adhere to<br />

the code, representing $36 trillion of<br />

assets under management. While these<br />

numbers paint a positive picture, is the<br />

Code adoption having any significant<br />

effects on FX market practices?<br />

Nordstrom’s comments suggest it is.<br />

“Many trading venues have reduced<br />

the maximum length of their “last<br />

look window,” a significant number<br />

of large bank dealers have announced<br />

an end to additional hold times, and<br />

several electronic trading platforms<br />

now offer trading venues from which<br />

non-Code-compliant liquidity providers<br />

are excluded,” she said in her speech.<br />

Nordstrom also noted the Chartered<br />

Financial Analyst program’s decision<br />

to reference the Code in its Level<br />

1 certification materials, lending<br />

further credibility. Past Code reviews<br />

have highlighted the importance of<br />

standardising Last Look and Pre-<br />

Hedging procedures.<br />

Recent modifications to the Code<br />

addressed settlement risk concerns.<br />

Lisa Danino-Lewis, Chief Growth<br />

Officer, CLS, explains. “The FX<br />

Global Code includes key principles<br />

concerning settlement risk (principles<br />

35 and 50) that emphasise the use<br />

of payment-versus-payment (PvP)<br />

settlement mechanisms where<br />

available,” she says.<br />

“It recommends the use of bilateral<br />

netting in cases where PvP settlement<br />

is not [available.] We continue to see<br />

growth in adoption of our products,<br />

CLSSettlement, Cross Currency Swaps,<br />

and CLSNet, that support market<br />

participants’ adherence to these<br />

principles.”<br />

And what do volumes look like?<br />

“CLSSettlement volumes have grown<br />

steadily with average daily values<br />

settled exceeding USD6.5 trillion<br />

across 18 currencies”, she says, “which<br />

accounts for a large proportion of FX<br />

trades in the market.”<br />

“In parallel, the adoption of CLSNet,<br />

CLS’s standardised bilateral netting<br />

calculation service, has continued to<br />

grow with the average daily notional<br />

value of net calculations consistently<br />

exceeding USD115 billion in the last 12<br />

months.”<br />

FX settlement risk will likely feature<br />

heavily in the GFXC’s latest Code<br />

review. While market participants will<br />

have to wait till <strong>January</strong> to understand<br />

how the GFXC will approach changes,<br />

the committee’s history of recent Code<br />

changes offers plenty of hints.<br />

In addition to the changes Danino-Lewis<br />

highlights, the GFXC also concluded<br />

that more frequent collection of FX<br />

settlement data through semi-annual<br />

surveys distributed by regional FX<br />

committees was wise.<br />

The committee also launched a<br />

working group led by the Bank of<br />

England to review and enhance<br />

existing FX settlement data collection<br />

templates. All this talk of settlement<br />

risk is leading to the issue of US T+1<br />

settlement, as the reader can guess.<br />

While the switch to T+1 was aimed<br />

at US equities, the FX impact is<br />

significant.<br />

LOOMING T+1 IMPLICATIONS<br />

FOR FX SETTLEMENT<br />

The Global Financial Markets<br />

Association notes that the foreign<br />

holding of US equities stood at USD<br />

12.1 Trillion in May 2023. Europe<br />

accounts for 48% of those holdings<br />

with Asia coming in second place<br />

at 22%. The move to T+1 doesn’t<br />

necessarily complicate the settlement<br />

picture as much as accelerates<br />

processes within it.<br />

CLS’s Danino-Lewis explains that<br />

a trade’s FX component will need<br />

settling before the equity portion. “To<br />

understand the potential impact of<br />

the move to T+1 for asset managers<br />

and funds accessing CLSSettlement<br />

through third-party service providers,<br />

CLS analysed its transaction data,” she<br />

says.<br />

“This analysis concluded that a value<br />

equivalent to approximately 1%<br />

of CLSSettlement’s average daily<br />

settlement value (USD6.5 trillion) is<br />

executed on a T+1 basis, comprising<br />

volumes where one side is USD, and a<br />

fund is a party to the trade.”<br />

“Therefore, the maximum value<br />

that may need to move to T+0<br />

after May <strong>2024</strong> by this community,<br />

is approximately USD 65 billion,<br />

assuming there are no trading and<br />

operational process changes by<br />

industry participants.”<br />

Walking through a sample scenario<br />

facing international asset managers<br />

is instructive in understanding T+1’s<br />

impact. A fund manager based in the<br />

EU must sell EUR and buy USD when<br />

JANUARY <strong>2024</strong> e-FOREX 15


FX measures the impact of the latest FX Global Code review and imminent move towards T+1 settlement<br />

“The FX Global Code includes key principles concerning<br />

settlement risk that emphasise the use of payment-versuspayment<br />

(PvP) settlement mechanisms where available”<br />

advances in artificial intelligence (AI) and<br />

robotic processing automation (RPA)<br />

offer great potential.”<br />

Penney reckons the FX market must<br />

indirectly through custodian banks<br />

that manage all payment instructions<br />

and funding relating to their clients’<br />

FX trades,” she says.<br />

evolve and embrace new products to<br />

overcome market structure challenges.<br />

“The good news is that FX is largely an<br />

automated industry and as such error<br />

rates are very low,” he says.<br />

“As part of this process, these custodian<br />

REGULATORY ISSUES<br />

Lisa Danino-Lewis<br />

purchasing US equity. The amount of<br />

USD they need will only be known<br />

when the equity transaction occurs.<br />

Assuming the equity trade occurs<br />

at the New York market close (9 PM<br />

GMT,) the fund manager must settle<br />

their trade the following day, making<br />

it a T0 settlement. The manager can<br />

settle through CLS, since EURUSD<br />

is CLS-enabled, mitigating any<br />

settlement risks.<br />

banks set their own cut-off times<br />

for CLS-related settlement to ensure<br />

adherence to CLS’s deadlines. CLS is also<br />

exploring how its services can assist in<br />

this issue and has conducted feasibility<br />

studies with both the buy side and<br />

sell side on adjusting CLSSettlement<br />

processes to accommodate later<br />

submission of instructions for<br />

settlement.”<br />

Automation will play a role here,<br />

Danino-Lewis says. “For instructions that<br />

do not meet CLS’s 00:00 CET deadline,<br />

CLSNet, can enhance post-trade<br />

efficiencies and mitigate risk.”<br />

“The service helps buy- and sellside<br />

participants reduce funding<br />

requirements and the number of<br />

“Equally, as automation increases<br />

amongst investment managers,” he<br />

continues, “the error rates generated<br />

from failed trades in securities markets<br />

will also drop significantly. Investment<br />

managers will have an increased need<br />

for cash liquidity, which could be fulfilled<br />

through new products, while credit and<br />

pricing mechanisms may need to be<br />

adjusted to a shorter time horizon.”<br />

In her speech at FX Markets USA last<br />

year, the New York Fed’s Nordstrom<br />

outlined a few considerations market<br />

participants will have to tackle. “FX<br />

market participants will need to<br />

carefully analyse their operational and<br />

liquidity management practices to avoid<br />

disrupting market functioning,” she said.<br />

However, the trade remediation window<br />

reduces significantly. The picture is<br />

even more complex for Asia-based<br />

asset managers. With markets closing<br />

before New York opens, T0 transactions<br />

are a given. However, the lack of CLS<br />

enablement in several Asian emerging<br />

currencies increases settlement risk.<br />

payments required by calculating net<br />

payment obligations that facilitate<br />

payment netting. CLSNet also<br />

enhances operational efficiencies<br />

through full automation, removing<br />

manual interventions from the netting<br />

calculation process.”<br />

Neill Penney, Group Head of FX, LSEG,<br />

“Stakeholders may also need to make<br />

substantial improvements to their<br />

existing operational systems and<br />

reconfigure FX settlement processes.<br />

An additional consideration is how<br />

T+1 will affect the values and volumes<br />

that currently settle through paymentversus-payment<br />

arrangements.”<br />

Fund managers will have to settle<br />

outside CLS while dealing with<br />

local market controls. One way of<br />

mitigating local control risks is to prefund<br />

the transaction, but this results in<br />

increased trading costs.<br />

expands on the technology theme.<br />

“There are aspects of the workflow<br />

change that are universal, especially<br />

when it comes to technology,” he says.<br />

“Without greater automation, firms<br />

will face a struggle with both their FX<br />

funding and hedging operations.”<br />

Nordstrom pointed out that while<br />

CLS can support this change, the<br />

volume of bilateral trade settlement<br />

outside CLS will increase, pushing<br />

settlement risk up. So, what are some<br />

of these considerations and how must<br />

stakeholders evaluate their processes?<br />

Danino-Lewis explains CLS has been<br />

working with market stakeholders to<br />

understand these risks better. “Asset<br />

managers access CLSSettlement<br />

“The key to a successful transition<br />

to the new environment will be the<br />

efficient transmission of data to both<br />

internal and external systems – and here<br />

KEY CONSIDERATIONS FOR A<br />

SMOOTH T+1 MOVE<br />

The first consideration that springs<br />

to mind is local currency cut-off<br />

16 JANUARY <strong>2024</strong> e-FOREX


Optimizing<br />

efficiency<br />

in post-trade<br />

processes<br />

In the new T+1 securities<br />

settlement era, achieving<br />

execution and operational<br />

efficiency in post-trade<br />

processes will be paramount<br />

for FX market participants.<br />

+ CLSMarketData<br />

Market participants can improve<br />

their understanding of market<br />

liquidity and risk positions through<br />

CLS’s comprehensive suite of<br />

data products – comprising<br />

the largest single source of<br />

aggregated FX executed data<br />

available to the market.<br />

+<br />

CLSTradeMonitor<br />

Asset managers and funds<br />

can achieve near real-time<br />

visibility of CLSSettlement<br />

instructions across their<br />

custodians and executing brokers,<br />

allowing for swift identification<br />

and resolution of exceptions.<br />

+<br />

CLSNet<br />

For instructions that do not meet<br />

CLS’s 00:00 CET deadline,<br />

CLS’s automated bilateral<br />

netting calculation service can<br />

help market participants to<br />

reduce their funding<br />

requirements and payment<br />

instructions and to enhance<br />

operational efficiencies.<br />

Find out more:<br />

cls-group.com<br />

JANUARY <strong>2024</strong> e-FOREX 17


FX measures the impact of the latest FX Global Code review and imminent move towards T+1 settlement<br />

REGULATORY ISSUES<br />

“Without greater automation, firms will face a struggle with<br />

both their FX funding and hedging operations.”<br />

times and holidays. Local central and<br />

commercial banks dictate currency<br />

settlement hours that affect settlement<br />

time windows.<br />

With each country adhering to<br />

different RTGS hours that govern<br />

currency cut-off times,) the challenge<br />

is one of coordination for asset<br />

managers. Correspondent bank<br />

hours and cut-offs also impact the<br />

settlement window.<br />

Neill Penney<br />

Technology and automated scheduling<br />

are obvious solutions to this puzzle<br />

and settlement risk. As Danino-<br />

Lewis explained, CLS has solutions,<br />

for trades that miss the 00:00 CET<br />

deadline, such as CLSNet which covers<br />

more than 120 currencies.<br />

Asset managers trading EM currencies,<br />

for instance, must account for<br />

additional credit lines and increased<br />

costs. Sticking with the EM theme,<br />

some of those currencies come<br />

with capital controls and trading<br />

restrictions.<br />

With trade remediation windows<br />

squeezed due to T+1, participants will<br />

have to plan execution avenues ahead<br />

of time. For instance, some currencies<br />

will need to be transacted through<br />

local exchanges that bring unique<br />

nuances to the picture.<br />

If the picture is too opaque, a<br />

prefunded mechanism to settle a T+1<br />

transaction might be the solution. Of<br />

course, this increases costs. The GFMA<br />

notes that some fund managers are<br />

establishing US-based operation hubs<br />

to smooth settlement, but this option<br />

might be excessive for smaller fund<br />

managers.<br />

The body notes in its report,<br />

“Consideration should also be given to<br />

the benefits of improving operational<br />

efficiencies, including investment<br />

in technologies that focus on the<br />

increased automation of processes,<br />

and to assessing the viability of<br />

using third-party vendors. Increased<br />

automation offers the advantages of<br />

operational efficiencies and could help<br />

to address the time-zone challenges.”<br />

“Trading platforms could also see an<br />

increase in demand for multi-asset<br />

trading and settlement capabilities,”<br />

it continues. “Simultaneous execution<br />

and increased process automation<br />

of equity and currency trades in<br />

tandem will assist in expediting the<br />

confirmation and settlement process<br />

required to meet the T+1 deadline.”<br />

The GFMA also notes that FX trading<br />

activity may increase towards the end<br />

of the New York day, a period where<br />

liquidity historically drops off. T0 FX<br />

trades may also spike, needing trading<br />

desks to pay special attention to<br />

funding needs.<br />

“Fund managers also aim to offer “best<br />

execution” and price transparency for<br />

their clients, often using the WMR 11am<br />

NY/4pm London benchmark to execute<br />

FX trades for international equity<br />

transactions,” GFMA’s report notes.<br />

“The amount of FX to be transacted<br />

is dependent upon the confirmed and<br />

matched equity transaction, which may<br />

not occur in time for a benchmark trade<br />

for T+1 settlement.”<br />

FX market participants will need to carefully analyse their operational and liquidity management practices<br />

“The risk of executing FX trades<br />

against unconfirmed/unmatched<br />

equity trades needs to be weighed<br />

18 JANUARY <strong>2024</strong> e-FOREX


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FX measures the impact of the latest FX Global Code review and imminent move towards T+1 settlement<br />

REGULATORY ISSUES<br />

“An additional consideration is how T+1 will affect the<br />

values and volumes that currently settle through paymentversus-payment<br />

arrangements.”<br />

up against the operational risks of<br />

increased trade amendments or<br />

cancellations.”<br />

Anna Nordstrom<br />

RISK AND COST IMPACT<br />

Given the shorter timeframe T+1<br />

creates, automation will prove critical<br />

for firms looking to mitigate risk.<br />

For instance, Standard Settlement<br />

Instruction (SSI) loading and verification<br />

will come under stress in a T+1<br />

environment. Sell-side firms will face<br />

limited timeframes to execute same-day<br />

account setups for new clients.<br />

Automating onboarding is one<br />

solution to this challenge. Automation<br />

can also solve issues in pre- and<br />

post-trade processing from KYC/AML<br />

checks and loading SSIs to matching<br />

and confirmation.<br />

In contrast, the buy side might find<br />

currency management challenging<br />

and could consider adopting passive<br />

currency strategies. Leveraging external<br />

providers with local market experience<br />

and access is another option.<br />

Most stakeholders will be keeping an<br />

eye on costs, given current market<br />

conditions. Pre-funding involving EM<br />

Asian currencies will increase costs.<br />

However, as interest rates rise, interest<br />

costs on late payments will likely have<br />

a significant impact.<br />

EU-based entities will have to<br />

contend with Central Securities<br />

Depositories Regulations (CSDR) that<br />

obligate them to disclose the adverse<br />

impact of late settlement fees.<br />

Infrastructure and workforce changes<br />

will also likely create a significant<br />

cost impact.<br />

With accelerated timelines in place,<br />

firms must consider augmenting<br />

existing roles with more personnel<br />

or introducing automation to the<br />

mix. Integrating these new roles with<br />

existing processes will need time,<br />

something that is a hidden cost.<br />

In some cases, shifting operations to a<br />

US-based location might make sense,<br />

despite high costs. If the impact of<br />

a smoother settlement reduces risk,<br />

firms could justify higher operational<br />

costs.<br />

THE ROLE OF TECHNOLOGY<br />

AND AUTOMATION<br />

Speaking of technology, Distributed<br />

Ledger Technology (DLT) offers a<br />

curious peek into what could be the<br />

future. DLT promises a T0 settlement,<br />

given the blockchain’s immutability.<br />

However, it isn’t in any usable shape<br />

for the institutional market and it lacks<br />

large scale industry adoption, as well<br />

as any proven track record, unlike<br />

existing solutions.<br />

Despite the current limitations of new<br />

technologies, such as DLT, one fact<br />

is for certain: greater automation of<br />

post trade practices using existing<br />

technology will help to solve any<br />

challenges firms face due to T+1<br />

settlement. How comprehensively<br />

firms automate their post trade<br />

services will prove critical in preparing<br />

successfully for T+1.<br />

Technology is poised to help solve many of the challenges firms face due to T+1 settlement<br />

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Image by Shutterstock<br />

Look-ahead:<br />

What lies in store for e-FX in <strong>2024</strong>?<br />

MARKET COMMENTARY<br />

Nicholas Pratt spoke to a number of key industry players about the year ahead<br />

to see what we should expect for the FX market in several important areas<br />

including settlement, digital assets, data analytics, algo trading and FX swaps.<br />

Vittorio Nuti<br />

VITTORIO NUTI, GLOBAL HEAD<br />

OF LD & FX ALGO TRADING<br />

AT DEUTSCHE BANK, ON FX<br />

ALGO TRADING & EXECUTION<br />

ANALYTICS:<br />

Algo execution in FX has been<br />

expanding at a decent pace over<br />

the last five to seven years, and I<br />

believe the product will enter a new<br />

phase in <strong>2024</strong>. This phase involves<br />

a slowdown in growth from the<br />

typical client base and an increase<br />

in hedge fund business. Hedge fund<br />

clients will be looking at execution<br />

more holistically, particularly<br />

considering the hidden costs of<br />

executing, such as co-located servers,<br />

IT costs for maintaining systems,<br />

and connections. This shift has the<br />

potential to change the landscape<br />

for FX algos.<br />

Regarding the development of<br />

new algos, we observe the FX algo<br />

business maturing, and we expect<br />

providers to differentiate their<br />

products by offering better quality<br />

of execution. This quality will be<br />

assessed quantitatively via third<br />

party TCA. As the client base will<br />

changes, further customisation of<br />

algo outcomes will be important<br />

to optimise client requirements. At<br />

Deutsche Bank, we’ll be focusing on<br />

delivering the successes achieved<br />

in FX to our Listed Derivatives<br />

platform.<br />

Balraj Bassi<br />

BALRAJ BASSI, CO-FOUNDER &<br />

CEO OF TRADEFEEDR, ON DATA<br />

ANALYTICS:<br />

22 JANUARY <strong>2024</strong> e-FOREX


MARKET COMMENTARY<br />

Data analytics in the FX market has now<br />

reached the point where clients have<br />

access to complete global data sets,<br />

capturing data from across multiple<br />

counterparties and venues, then making<br />

it available for analysis. We expect that<br />

<strong>2024</strong> to be the year where these data<br />

sets change how counterparties interact<br />

with each other and enable increased<br />

automated trading workflows.<br />

far more fragmented than in FX.<br />

Firms want to receive market data<br />

and execute first. Co-location is<br />

becoming essential and given the<br />

rate of change of venue offerings,<br />

trading firms require active 24/7/365<br />

support.<br />

As more information becomes available<br />

on data networks, it is now easier than<br />

ever for buy-side and sell-side firms<br />

to interact and collaborate, to make<br />

informed decisions about who they<br />

trade with and how they execute trades<br />

most effectively and profitably.<br />

This is far beyond Transaction Cost<br />

Analysis (TCA), as trading data is now<br />

available to inform trading decision<br />

making in pre-trade.<br />

Automation is a key trend for <strong>2024</strong>.<br />

During Q4 last year we started to see<br />

some clients’ trading desks automate<br />

their workflows using the information<br />

contained in our data network. As<br />

an example, we see this with our<br />

Algo Forecasting model, which uses<br />

performance data from FX execution<br />

algos to identify the most appropriate<br />

algo for specific orders.<br />

Clients use this in pre-trade to select<br />

specific execution algos, and some firms<br />

are automating this whole process,<br />

using APIs to gather forecasts on specific<br />

trades before automatically sending<br />

orders to execution algos. As firms<br />

look to increase workflow efficiency,<br />

we expect this type of automation to<br />

increase in <strong>2024</strong>.<br />

As firms increasingly use data in all<br />

parts of their trading, we have seen<br />

demand for data networks supporting<br />

multiple asset classes. Tradefeedr’s initial<br />

focus was FX, but in response to client<br />

requests we will launch Equities and<br />

Futures in <strong>2024</strong>.<br />

Rob Wing<br />

ROB WING, HEAD OF DIGITAL<br />

ASSETS & FX AT 4OTC:<br />

Over the past two years we have<br />

seen more financial institutions move<br />

into digital assets trading. We expect<br />

this to continue during <strong>2024</strong>, as<br />

investors continue to diversify their<br />

portfolios with a range of crypto<br />

assets, including Bitcoin, Ethereum<br />

and other more established crypto<br />

currencies.<br />

The recent SEC approval of Bitcoin<br />

ETFs will make it significantly easier<br />

for large pools of institutional capital<br />

to be deployed, pushing Bitcoin<br />

prices higher (with some predicting a<br />

new all-time high). What is certain is<br />

that there will be renewed interest in<br />

some of the more established crypto<br />

currencies.<br />

The market remains highly<br />

fragmented, with institutional<br />

traders typically connecting to<br />

between five and 25 exchanges<br />

globally to access market data and<br />

liquidity. As with other asset classes,<br />

firms are demanding institutionalgrade<br />

infrastructure to access these<br />

markets in the form of robust,<br />

secure, and low latency connectivity.<br />

They also require failover and<br />

full disaster recovery procedures.<br />

The digital assets markets are<br />

Lisa Danino-lewis<br />

LISA DANINO-LEWIS, CHIEF<br />

GROWTH OFFICER AT CLS, ON<br />

FX SETTLEMENT:<br />

Exploring ways to tackle rising<br />

settlement risk in emerging market<br />

(EM) currencies will continue to be a<br />

priority for the FX market next year.<br />

Adding currencies to CLSSettlement<br />

requires ongoing support from the<br />

relevant central bank and can require<br />

changes in the jurisdiction’s laws.<br />

Given these challenges, CLS will<br />

continue to focus its efforts on<br />

addressing this issue by enhancing<br />

CLSNet, our standardized, automated<br />

bilateral payment netting calculation<br />

service across 120 currencies. CLSNet<br />

reduces payment obligations exposed<br />

to settlement risk while improving<br />

operational and liquidity efficiencies.<br />

With an implementation date of 28<br />

May <strong>2024</strong>, supporting FX market<br />

participants through the move to T+1<br />

securities settlement in the US and<br />

JANUARY <strong>2024</strong> e-FOREX 23


Look-ahead: What lies in store for e-FX in <strong>2024</strong>?<br />

MARKET COMMENTARY<br />

Canada will be another priority next<br />

year. As 20% of US securities and<br />

16% of US equities are held in foreign<br />

portfolio holdings, the move to T+1 will<br />

impact many cross-border transactions.<br />

This is because to settle cross-border<br />

securities on T+1, the FX component<br />

of the transaction needs to be settled<br />

prior to the settlement of the security.<br />

CLSSettlement can support the trade<br />

flows resulting from a move from<br />

T+2 to T+1. However, time zone and/<br />

or operational constraints may require<br />

some cross-border market participants<br />

to adjust their FX post trade practices<br />

in order to meet T+1 requirements.<br />

CLS is engaging with both sell- and<br />

buy-side clients to explore how<br />

our current suite of products can<br />

assist the market in the shortterm<br />

and consider the feasibility of<br />

adjusting CLSSettlement processes<br />

to accommodate later cut-off<br />

times. However, our main priority is<br />

maintaining the stability of the FX<br />

ecosystem, so any adjustments will<br />

need to be carefully considered.<br />

Dirk Bullmann<br />

DIRK BULLMANN, GLOBAL<br />

HEAD OF PUBLIC POLICY AT<br />

CLS, ON DEVELOPMENTS<br />

AROUND CENTRAL BANK<br />

DIGITAL CURRENCIES (CBDCS):<br />

Since the term ‘CBDC’ was coined<br />

almost a decade ago, there has<br />

been increasing engagement<br />

globally by both the public and<br />

private sector in CBDC research<br />

and experimentation. In 2023, we<br />

observed an increasing focus on<br />

wholesale CBDC and saw some<br />

significant advances in the work<br />

around cross-border payments.<br />

We expect wholesale crossborder<br />

CBDCs to continue to be a<br />

significant theme for the coming<br />

year. As CLS provides a multicurrency,<br />

cross-border and wholesale<br />

payment system, which forms the<br />

settlement backbone of the global<br />

FX market, those developments are<br />

particularly relevant for us.<br />

We have established an innovation<br />

lab to follow and support CBDC and<br />

other initiatives where relevant. CLS<br />

is for example among a group of 30<br />

financial institutions participating in<br />

a second phase of the SWIFT CBDC<br />

sandbox testing to explore FX and<br />

other use cases.<br />

As regards the use of new<br />

technologies such as DLT, we are<br />

always evaluating new opportunities<br />

to deliver enhanced services to<br />

our clients and mitigate risk in<br />

the FX market. However, any new<br />

technological solution must deliver<br />

efficiencies and/or reduce costs<br />

while also meeting extraordinarily<br />

high standards of resilience.<br />

Technology can only transform the<br />

market when it is translated into<br />

solutions that solve real business<br />

problems. That requires a deep<br />

understanding of business processes<br />

and platforms, and for activities<br />

currently undertaken by FMIs,<br />

such as CLS, the correct levels of<br />

oversight, governance, credibility<br />

and trust.<br />

Peer Joost<br />

PEER JOOST, CEO OF DIGITEC,<br />

ON DEVELOPMENTS IN THE FX<br />

SWAPS MARKET:<br />

Technology will be the key theme<br />

of <strong>2024</strong>. With increasing trading<br />

volumes, greater involvement from<br />

banks of all sizes and further buy-side<br />

participation, the FX Swaps market<br />

will continue its rapid volume growth<br />

and migration to electronic channels.<br />

This will drive further demand for<br />

accurate and robust pricing engines,<br />

and more automated end-to-end<br />

workflows. Staying ahead of the game<br />

will require much faster adoption of<br />

technology than we’ve seen in the<br />

past and this can only be achieved by<br />

frequently updated and scalable SaaS<br />

solutions.<br />

We will continue to see banks of all<br />

sizes moving away from spreadsheetbased<br />

or manual pricing, and instead<br />

implementing accurate and robust<br />

pricing engines. These are required<br />

to accurately price in the rapidly<br />

moving electronic FX markets. Pricing<br />

FX Swaps is complex, and the scale<br />

of the challenge is demonstrated<br />

by Market Maker banks typically<br />

calculating 20,000 prices along their<br />

forward curve.<br />

Automating workflows is another key<br />

trend for <strong>2024</strong>, which will drive the<br />

further adoption of technology. All<br />

24 JANUARY <strong>2024</strong> e-FOREX


MARKET COMMENTARY<br />

banks and the buy-side are already<br />

looking to improve automation<br />

throughout the trade lifecycle, to<br />

cut costs and have the capacity to<br />

manage more client business. Client<br />

demand to trade FX Swaps across<br />

more currencies and dates is growing<br />

and banks are looking for efficient<br />

ways to manage that additional<br />

volume.<br />

The importance of data will grow as<br />

more pricing engines are implemented<br />

and more banks automate workflows.<br />

We continue to see more banks using<br />

the Swaps Data Feed (SDF). For banks<br />

and traders to fully build and maintain<br />

their own curves, the SDF allows<br />

them to improve pricing and extend<br />

currency coverage.<br />

We also expect to see an increase<br />

in the electronic trading of these<br />

instruments in <strong>2024</strong>. As clients look<br />

to FX Swaps as a source of global<br />

funding there is demand for their<br />

relationship banks to provide liquidity<br />

across multiple currencies and tenors.<br />

The only realistic way for banks to<br />

manage this client business in an<br />

efficient way is by trading using<br />

electronic channels, and automating<br />

workflows - in data, pricing,<br />

distribution, and settlement.<br />

As the FX Swaps market continues to<br />

grow, we also expect to see regional<br />

banks trade more FX Swaps. In the<br />

past many could not justify the<br />

investment in on-premise applications,<br />

but with SaaS apps deployed in the<br />

cloud they are increasingly adopting<br />

FX Swaps pricing technology to<br />

service their client needs. This pricing<br />

technology enables regional banks<br />

to price more accurately and faster<br />

– both of which are essential for<br />

electronic markets.<br />

Electronification and automation<br />

result in better pricing along the<br />

curve, more clients serviced, more<br />

currencies traded, and more quotes<br />

accurately auto-priced – leading<br />

to increased trading volumes and<br />

improved client service. Typically,<br />

when a regional bank goes live with<br />

our D3 solution combined with the<br />

SDF, they are able to expand their<br />

offering beyond G10 and specialist<br />

currencies.<br />

Electronic trading increases the need<br />

for accurate pricing and any bank<br />

publishing a wrong price is likely to<br />

quickly lose money. As banks look to<br />

attract more business electronically,<br />

we are already seeing tighter prices,<br />

but the main theme is that price<br />

accuracy along the forward curve has<br />

improved significantly.<br />

In <strong>2024</strong> Interdealer trading of FX<br />

Swaps, which has traditionally been<br />

dominated by the broker market,<br />

will start to migrate to electronic<br />

venues like 360T and LSEG. After<br />

our recent launch of D3 OMS we<br />

are seeing significant interest as<br />

banks look to access these venues<br />

to efficiently manage risk positions.<br />

As a result, we expect to see<br />

increased volumes on electronic<br />

interbank matching platforms,<br />

which will drive increased market<br />

liquidity, greater participation,<br />

improved client pricing and risk<br />

management, and for the FX Swaps<br />

market to grow for the benefit of<br />

all parties.<br />

FINALLY, JEFF WARD, CEO<br />

AT FXSPOTSTREAM, TALKS<br />

ABOUT THE KEY TECHNOLOGY<br />

DECISION THIS LEADING<br />

PROVIDER WILL BE MAKING IN<br />

<strong>2024</strong>.<br />

When considering developments in the<br />

FX market, it is important to note that<br />

these do not happen overnight, and<br />

the trends are already in place. In 2023,<br />

we began reporting our spot volumes<br />

Jeff Ward<br />

separately and found that, while spot<br />

had remained fairly flat compared to<br />

our record year in 2022 – we actually<br />

saw strong growth in other products,<br />

namely NDFs (up 42.05% from an ADV<br />

perspective in 2023 vs 2022).<br />

As with any service, a growth in<br />

volumes can come in one of two ways:<br />

through new additions, whether that<br />

be in the form of new clients or adding<br />

new liquidity providers (LPs), or through<br />

working with clients to maximize their<br />

relationships with their LPs. FX is, and<br />

always has been, a relationship driven<br />

business and understanding what<br />

each side is thinking puts us in a great<br />

position to help.<br />

As with any technology provider, there<br />

are several technology decisions we<br />

will have to make in <strong>2024</strong>. Last year<br />

we embarked on our ultralow-latency<br />

network migration and this year will<br />

move on to the next phase of the<br />

project, specifically the order entry and<br />

order confirmation processing.<br />

Whenever we make a decision for<br />

the company, there are obvious risk<br />

versus reward questions, and ultimately<br />

the biggest driver in these is usually<br />

the value added for the client and/<br />

or FXSpotStream LPs. We maintain a<br />

constant dialogue with both sides and<br />

are always looking for ways to improve<br />

their experience.<br />

JANUARY <strong>2024</strong> e-FOREX 25


The growth of CLSNet:<br />

The next best thing<br />

after CLSSettlement<br />

By Marc Bayle de Jessé, CEO of CLS.<br />

grapples with these challenges, CLS’s<br />

role in managing settlement risk,<br />

especially for currencies not eligible for<br />

CLSSettlement, becomes increasingly<br />

crucial.<br />

has been the asset management<br />

community. Asset managers access<br />

CLSSettlement via settlement members<br />

that provide third-party services, as<br />

do other indirect participants like<br />

PROVIDER VIEWPOINT<br />

Marc Bayle de Jessé<br />

As emerging market (EM) currencies<br />

Settlement risk remains one of the<br />

most significant risks in the FX market<br />

today. CLS currently settles 18 of<br />

the most actively traded currencies<br />

globally, for over 70 settlement<br />

members comprising the world’s<br />

leading financial institutions and<br />

over 35,000 indirect third-party<br />

participants.<br />

corporates, banks and non-bank<br />

financial institutions. Notably, almost<br />

80% of the top 250 investment<br />

managers are now settling through<br />

CLSSettlement via their custodian<br />

banks 1 .<br />

To gain further insight into the<br />

pockets of remaining settlement risk,<br />

CLS collaborated with a subset of its<br />

settlement members to analyze their<br />

continue to outpace the market in<br />

terms of growth, the FX market has<br />

seen renewed attention towards<br />

reducing FX settlement risk.<br />

Policymakers and regulators are<br />

exploring ways to expand paymentversus-payment<br />

(PvP) settlement to<br />

currencies for which it is not currently<br />

available. This heightened concern<br />

about mitigating FX settlement risk<br />

CLSSettlement is the industry’s<br />

settlement risk success story. It was<br />

created to mitigate FX settlement<br />

risk by providing PvP settlement. PvP<br />

ensures the final transfer of a payment<br />

in one currency occurs if, and only if,<br />

the final transfer of a payment in the<br />

counter currency (or currencies) takes<br />

place.<br />

FX trades and determine how they<br />

were settled. The findings indicated<br />

how the market manages settlement<br />

risk and the range of mechanisms<br />

used to settle FX flows. It showed<br />

that around 90% of the settlement<br />

risk exposure associated with their<br />

FX trades in the 18 CLS-eligible<br />

currencies was successfully mitigated<br />

via CLSSettlement with full PvP.<br />

has sparked industry discussions about<br />

how best to address it.<br />

FX settlement risk is sensitive to today’s<br />

growing geopolitical challenges as well<br />

as market and economic turbulence.<br />

Amid this backdrop, market<br />

participants are seeking to maximize<br />

liquidity and minimize risk in their FX<br />

settlement practices. As the industry<br />

Recent CLSSettlement growth<br />

statistics demonstrate that CLS is<br />

achieving what it set out to do. In<br />

2023, CLS settled an average daily<br />

value of USD6.6 trillion of FX payment<br />

instructions, and in December, it<br />

settled a new daily record of USD16.3<br />

trillion (previous record was USD15.3<br />

trillion on 15 December 2021). A<br />

major contributor to this growth<br />

Successful settlement risk mitigation<br />

has been achieved for CLS-eligible<br />

currencies. However, with the growth<br />

in EM currency trading, the remaining<br />

challenge is to mitigate settlement<br />

risk for currencies ineligible for PvP<br />

settlement. Given CLS’s systemic<br />

importance, adding new currencies to<br />

the settlement service is an extended<br />

26 JANUARY <strong>2024</strong> e-FOREX<br />

1 Excluding Chinese based investment managers


PROVIDER VIEWPOINT<br />

effort that requires ongoing support<br />

from the relevant central bank and the<br />

industry, and the target jurisdiction’s<br />

laws and regulations may need to be<br />

changed.<br />

CLS has been exploring ways to<br />

expand PvP coverage. However, to<br />

achieve progress in this area, public<br />

and private sector stakeholders will<br />

need to closely collaborate over<br />

multiple years to overcome regulatory<br />

and geopolitical challenges and arrive<br />

at an industry solution.<br />

For now CLS is focusing on enhancing<br />

CLSNet, its automated bilateral<br />

payment netting calculation service<br />

for over 120 currencies. CLSNet helps<br />

to mitigate operational risk for EM<br />

currency trades. By standardizing and<br />

automating the netting calculation<br />

process, it facilitates the reduction<br />

of payment obligations exposed<br />

to settlement risk while improving<br />

operational and liquidity efficiencies.<br />

Moving forward, CLS’s priority will<br />

be to enhance CLSNet’s functionality<br />

even further to effectively address<br />

settlement risk for EM currencies.<br />

Public policy efforts have focused on<br />

the issue of mitigating settlement<br />

risk. Building block 9 of the Financial<br />

Stability Board’s cross-border roadmap<br />

focuses on increased adoption of<br />

PvP settlement. The FX Global Code,<br />

published by the Global Foreign<br />

Exchange Committee, includes key<br />

principles concerning settlement risk<br />

(principles 35 and 50) that emphasize<br />

the use of PvP settlement mechanisms<br />

where available and recommend the<br />

use of bilateral netting in cases where<br />

PvP settlement is not available.<br />

CLSNet supports adherence to these<br />

principles, as trade details sent to<br />

CLSNet are validated and matched<br />

up to the pre-determined cut-off<br />

times between counterparties for<br />

each currency. This ensures that only<br />

confirmed trade details are included<br />

in the automated net calculation and<br />

that there is a single common record<br />

of the net payment obligations. By<br />

automating the netting process via<br />

a centralized platform, participants<br />

benefit from greater operational<br />

efficiency and increased risk<br />

mitigation for currencies currently<br />

unable to settle in CLSSettlement.<br />

CLS believes that the true benefits<br />

of the bilateral netting calculation<br />

process can only be realized with<br />

an industry utility model that<br />

is centralized and standardized,<br />

underpinned by an underlying<br />

rulebook. Crucially, these types of<br />

conditions are most likely to produce<br />

the network effect, which is essential<br />

if such services are to deliver optimal<br />

benefits to FX market participants.<br />

Recent CLSSettlement growth<br />

statistics demonstrate that CLS is<br />

achieving what it set out to do. In<br />

2023, CLS settled an average daily<br />

value of USD6.6 trillion of FX<br />

payment instructions, and in<br />

December, 2023 reached a record of<br />

USD445 billion netted. The growing<br />

CLSNet community already includes<br />

eight of the top ten global banks 2 ,<br />

and extending the network to more<br />

banks, funds, corporates and nonbank<br />

financial institutions is a priority<br />

for the coming year. CLS is confident<br />

that the tangible benefits of the<br />

service will continue to drive uptake<br />

of the service.<br />

Further, when the US and Canadian<br />

securities markets move to T+1<br />

settlement in May <strong>2024</strong>, the asset<br />

manager community and other market<br />

participants will face new challenges<br />

with the FX post-trade lifecycle,<br />

including time constraints that may<br />

limit the use of CLSSettlement.<br />

CLSNet can help to reduce funding<br />

requirements and payment instructions<br />

by calculating net payment obligations<br />

that facilitate payment netting.<br />

CLSSettlement is doing what it set<br />

out to do: mitigate FX settlement<br />

risk. Growth numbers and settlement<br />

risk analysis demonstrate the strong<br />

industry support for the service.<br />

Settlement risk is largely mitigated for<br />

CLS-eligible currencies.<br />

With the growth in EM currency<br />

trading, the remaining challenge is<br />

how best to mitigate risk for currencies<br />

ineligible for PvP settlement. For<br />

now, we believe this is CLSNet.<br />

Recent growth reflects the industry’s<br />

support for the service and its need<br />

for a centralized, standardized, and<br />

automated process that enables them<br />

to mitigate operational risk, optimize<br />

liquidity and create operational<br />

efficiencies. CLS’s role is to continue<br />

building the CLSNet community – a<br />

key priority for <strong>2024</strong>.<br />

2<br />

Euromoney Global FX Survey 2022<br />

JANUARY <strong>2024</strong> e-FOREX 27


Exploring the state of<br />

e-FX and associated<br />

fintech in Southern Africa<br />

REGIONAL E-FX PERSPECTIVE<br />

Analysing the state of e-FX in Africa is always a challenging task. The<br />

continent’s diversity prevents observers from identifying any unifying<br />

trends. However, one can safely say that electronification is increasing<br />

throughout the continent, even in sub-regions where voice and manual<br />

RFQs dominate. Vivek Shankar investigates.<br />

Image by Shutterstock<br />

28 JANUARY <strong>2024</strong> e-FOREX


REGIONAL E-FX PERSPECTIVE<br />

JANUARY <strong>2024</strong> e-FOREX 29


Exploring the state of e-FX and associated fintech in Southern Africa<br />

“We see great potential for expansion of electronification<br />

across the board where many African countries still have a<br />

large portion of the FX execution done on a manual basis,”<br />

price distribution have been key focus<br />

points.”<br />

electronification on a continental<br />

level is huge. “We see great potential<br />

for expansion of electronification<br />

across the board where many African<br />

countries still have a large portion of<br />

the FX execution done on a manual<br />

basis,” he says.<br />

Electronification has particularly<br />

“With the use of already developed<br />

touched corporate treasury activity in<br />

infrastructure that can support the<br />

the continent’s more mature markets,<br />

management and price creation for<br />

such as South Africa. Naturally, this<br />

local market currency pairs, both<br />

wave has brought unique risks with it.<br />

the buy and sell sides would tend to<br />

move towards transparency and faster<br />

“Best execution in emerging markets<br />

execution that electronic FX trading<br />

can mean different things,” says<br />

provides.”<br />

REGIONAL E-FX PERSPECTIVE<br />

Ryan Tolmay<br />

“It’s no secret that Africa has embraced<br />

technology, and this can be seen in<br />

the adoption of digital payments and<br />

mobile money services,” says Ryan<br />

Tolmay, Sales Manager, Africa Sub<br />

Sahara at 360T. “This cultural change<br />

has pushed the sell side to look at what<br />

digital services they offer their clients<br />

and trading is no exception.”<br />

“From a bank standpoint,” he<br />

continues, “we see that there has been<br />

a focus on their internal workflows.<br />

The ease of access to and adoption<br />

of technology to optimise specific<br />

areas including liquidity sourcing and<br />

Tim Hutchinson, Head of Electronic<br />

Execution and FX, Markets at Rand<br />

Merchant Bank (RMB.) “The choppiness<br />

of the liquidity, the fact that few<br />

regional players can market make<br />

certain currencies, all of whom are<br />

at different stages of their electronic<br />

trading journey, puts corporates in an<br />

interesting position.”<br />

Is electronification posing more<br />

challenges than it solves in African<br />

e-FX? Here’s a look at how market<br />

participants are handling them and<br />

what moves we may see soon.<br />

ELECTRONIFICATION IS NOT A<br />

SILVER BULLET<br />

Tolmay notes that the potential for<br />

However, Hutchinson is quick to point<br />

out that electronification doesn’t solve<br />

issues automatically. Corporates have<br />

realised the benefits of automating<br />

execution and are now exploring its use<br />

for other treasury activities.<br />

The goal here, Hutchinson notes, is<br />

to give more time back to treasury<br />

departments that enable value-added<br />

work. But just utilising electronic<br />

channels doesn’t guarantee a client<br />

best execution.<br />

“It’s been quite fascinating to watch<br />

how Request for Quote tickets from<br />

clients on a multi-dealer platform sit<br />

open for quite some time,” he says.<br />

“This tells me that not all of those<br />

banks can handle client requests in<br />

an automated fashion. As a result,<br />

clients are disadvantaged here because<br />

markets by their nature are moving<br />

continuously. This is something we’re<br />

encouraging our clients to be curious<br />

about when using the likes of a<br />

multi-bank-portal seeking to get best<br />

execution. Clients may not have the<br />

tools to automatically scan a best<br />

execution report, but being curious<br />

about what they’re seeing from their<br />

banks pricing behaviour is beneficial.”<br />

Corporates have realised the benefits of automating execution and are now exploring its use for other treasury activities<br />

He lists a few examples of events to<br />

look at. “Why certain banks take longer<br />

30 JANUARY <strong>2024</strong> e-FOREX


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JANUARY <strong>2024</strong> e-FOREX 31


Exploring the state of e-FX and associated fintech in Southern Africa<br />

REGIONAL E-FX PERSPECTIVE<br />

“Clients may not have the tools to automatically scan a best<br />

execution report, but being curious about what they’re<br />

seeing from their banks pricing behaviour is beneficial.”<br />

Tim Hutchinson<br />

to price back than others, how often<br />

price updates are generated, how their<br />

requests are handled at different times<br />

of the day as well as the consistency in<br />

decimal places within quotes between<br />

providers. It may sound simplistic, but<br />

banks that quote manually tend to<br />

quote up to four decimal places since<br />

the Dollar-Rand is priced that way in<br />

the matching market.”<br />

“Banks with electronic quoting abilities<br />

go up to five places,” he continues.<br />

“These are some of the things we’ve<br />

been encouraging treasurers to be<br />

much more conscious of.”<br />

The core issue here is the definition of<br />

best execution. What does that phrase<br />

mean specifically when dealing in an<br />

emerging market? Treasurers will find<br />

going back to first principles useful<br />

when figuring this out. First, given<br />

southern and broader Africa’s market,<br />

receiving optimal liquidity is critical<br />

and is an important pillar within best<br />

execution.<br />

Analysing a trade’s market impact is<br />

also critical. Execution report analysis<br />

will offer insights into this factor. Lastly,<br />

treasurers must ask whether they<br />

received the best price. Typically, market<br />

participants rush toward just this factor,<br />

so analysing it is logical.<br />

Hutchinson’s point about quotes sitting<br />

on MDPs for far too long highlights<br />

how manual execution delivers less<br />

than optimal execution. For instance,<br />

most MDPs offer price refreshes four<br />

times per second. Assuming a manual<br />

quote takes 5 seconds to put together,<br />

clients are exposed to 20 price changes.<br />

“All of this pushed us to have more<br />

conversations with clients about<br />

different execution styles and what’s<br />

best suited for you,” Hutchinson says.<br />

“What do the differences between RFQ<br />

and Request for Stream (RFS) look like,<br />

and what is their impact on clients and<br />

their executions?”<br />

FIGURING OUT THE BEST FIT<br />

Getting a hold of all the factors<br />

corporates must look for in a bank<br />

partner can seem intimidating.<br />

Hutchinson has spoken about looking<br />

at internalisation rates in the past and<br />

encourages his clients to ask questions<br />

about them.<br />

He defines the internalisation rate as<br />

the percentage of risk a bank passively<br />

trades out with its other clients,<br />

with a higher rate indicating better<br />

performance. Notably, this definition<br />

doesn’t hold across each bank.<br />

These definition changes occur due to<br />

the diversity of liquidity providers banks<br />

access, all with different degrees of<br />

sophistication. Banks that seek to exit<br />

risk into the market tend to produce<br />

the highest market impact for clients,<br />

and looking for this quality is critical<br />

from a treasurer’s perspective.<br />

“Data is critical,” Hutchinson says.<br />

“Internalisation rates, price markouts<br />

of execution, holding times of trades<br />

for internalisation rates by deal and<br />

ticket sizes are a few data sets that are<br />

important.”<br />

He adds that the client’s willingness to<br />

work with the e-FX desk at their bank<br />

to design workflows fit for purpose<br />

is also important. There’s an entirely<br />

new dynamic in how the market now<br />

operates versus a few years back [in<br />

particular the Dollar/Rand market ], and<br />

clients will benefit from understanding<br />

how banks value client flow and what<br />

can be done so that both parties<br />

benefit.”<br />

Recently, algorithmic (algo) trading has<br />

emerged as a potential solution for<br />

illiquidity and reducing market impact.<br />

What does this picture look like in<br />

South Africa?<br />

“It’s in its infancy in the local market,”<br />

Hutchinson says. “Local banks haven’t<br />

brought much to the market for a few<br />

reasons. One, it is a big investment<br />

(even on a white labelled basis), and<br />

not every bank is at that stage of its<br />

journey to justify that cost.”<br />

“Illiquidity and choppiness in the<br />

Rand market are also a factor,” he<br />

adds. Treasurers are also not (as yet)<br />

fully versed with algo workflows, and<br />

this contributes to the low uptake.<br />

Hutchinson notes that with global<br />

banks setting up shop in South Africa,<br />

algo trading practices ought to expand<br />

more locally.<br />

HANDLING CENTRAL BANK<br />

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Outside of South Africa there are<br />

additional challenges unique to the<br />

continent. Currently, the African<br />

banking landscape is a mix of regional<br />

players and Super Regional banks<br />

who operate local liquidity centres of<br />

excellence.<br />

32 JANUARY <strong>2024</strong> e-FOREX


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Exploring the state of e-FX and associated fintech in Southern Africa<br />

continuation of infrastructure<br />

development, and of course, local<br />

demand.”<br />

REGIONAL E-FX PERSPECTIVE<br />

Clients will benefit from understanding how banks value client flow and what can be done so that both parties benefit<br />

Central banks tend to guide the<br />

markets based on their counterparty Hutchinson notes that banks<br />

liquidity transfer expectations. This have witnessed some interesting<br />

approach works well in a voice-driven developments, like rethinking the role<br />

and manual environment. Relationships of central pricing engines. While these<br />

with the central bank lead to a better engines deliver prices and maintain<br />

understanding of their expectations, spread guidelines to clients, can they be<br />

ensuring compliance.<br />

used to interact with central banks too?<br />

As banks increasingly pursue<br />

“I think what makes it challenging<br />

electronification this introduces an is the complexity behind these e-FX<br />

entirely new dynamic of how best mechanisms,” he says. “Identifying<br />

to ensure compliance. Hutchinson clients and identifying which central<br />

explains. “You’ll find (as an example) bank guidelines to apply to them, etc is<br />

a client who has a footprint across complicated and might result in some<br />

East and West Africa, may wish to breakage.”<br />

maintain a relationship with their bank<br />

across markets seeking to establish “It’s a really interesting dynamic in our<br />

consistency in operations . However, local market right now,” he continues,<br />

due to the dynamics unique to those “where we’re not trying to just<br />

markets or internal capability rollouts, optimise prices for clients, but also align<br />

you’ll find that service offerings aren’t with what central banks are looking for.<br />

very consistent across subsidiaries.” We have to make them comfortable<br />

that despite moving onto this digital<br />

He mentions that RMB has been platform that can sometimes run<br />

working to increase consistency across autonomously, we can maintain their<br />

multiple markets through its e-FX guidelines.”<br />

tooling. While better experiences are<br />

being created, this attempt has come Banks have a significant role to<br />

with certain challenges. “A lot of e-FX play here in terms of education.<br />

capabilities don’t naturally consider 360T’s Tolmay is bullish about<br />

elements such as central bank spread electronification’s growth prospects.<br />

guidelines, compliance with pre trade “Growth is expected from the more<br />

quote guidelines etc,” he says. “We’re mature markets on the continent,”<br />

being challenged as a market to think he says. “Drivers will include the<br />

about doing these things.”<br />

local regulatory environment, the<br />

While the markets in southern Africa<br />

have traditionally been more advanced,<br />

Tolmay says his attention is focused<br />

on other areas. “We expect continued<br />

expansion of electronic trading to<br />

continue in southern Africa where the<br />

FX markets have traditionally been<br />

more advanced. However, the uptake in<br />

both East and West Africa may prove to<br />

be key in the coming years.”<br />

Electronification can drive more<br />

transparency for central banks, giving<br />

them insights into customer demand.<br />

And with these insights come more<br />

demand for innovative products that<br />

offer transparency into different market<br />

functions.<br />

THE NDF PICTURE AND WHAT<br />

THE FUTURE HOLDS<br />

NDFs have traditionally received less<br />

demand in Africa. However, the NDF<br />

market is relatively young, with the<br />

first African NDF executed as recently<br />

as 2019 by Bank of America and Citi.<br />

Hutchinson says RMB has noticed a<br />

growth spurt in demand.<br />

“The appetite is coming from a few<br />

places, but where we definitely see<br />

demand coming from is the offshore<br />

buy side,” he says. RMB’s position as<br />

a super-regional bank and its work<br />

in expanding distribution has led to<br />

its presence in multiple offshore FX<br />

venues. As these FX venues moved<br />

towards NDF, demand has grown,<br />

Hutchinson says. “A lot of these<br />

venues have made significant strides<br />

in Asia and LATAM NDFs. Naturally,<br />

they’re looking for the next growth<br />

phase which they see as Africa. We<br />

are in the process of activating our<br />

NDF market making capabilities on<br />

these venues to compliment our very<br />

successful USDZAR cash market making<br />

capability.”<br />

34 JANUARY <strong>2024</strong> e-FOREX


REGIONAL E-FX PERSPECTIVE<br />

He notes there are a few hurdles<br />

around regulations. For instance, US<br />

swap dealing regulations might lead<br />

some banks to build relationships with<br />

prime brokers to mitigate regulatory<br />

concerns. “We also see central clearing<br />

models that some venues are offering<br />

as an interesting way of accessing<br />

clients,” he says.<br />

Hutchinson believes the NDF market<br />

is set to grow and is bullish about<br />

African e-FX’s potential in the near<br />

term. “Client conversations have<br />

shifted toward increasing efficiency<br />

and electronification is a part of<br />

that,” he says. “On an RMB level,<br />

I’m excited because we’ve been on<br />

this journey for a while now and the<br />

benefit it has for our next level of<br />

innovation.”<br />

With more data and robust processes<br />

in place, banks can hope to engage<br />

more with markets and central banks.<br />

Electronification may lag in African<br />

e-FX, but it is nonetheless creating a<br />

rosy future for market participants.<br />

FINTECH INCREASINGLY MAKES<br />

IT MARK ON THE INSTITUTIONAL<br />

SPACE<br />

Fintech’s focus on Africa has largely been on payments.<br />

Specifically, cross-border payments have benefited from<br />

the injection of technology that fintechs have brought<br />

to the market. The institutional picture extended this<br />

advantage, giving clients access to wholesale FX rates<br />

and payment platforms.<br />

salesperson operating on behalf of a client using a voice<br />

channel or a client seeking to self-service on a digital<br />

platform, we want to preserve the level of pre-trade<br />

checks needed.”<br />

Traditionally banks have codified these checks in their<br />

pricing engines, leading to a rigid structure incompatible<br />

with modern markets. RMB has been working with<br />

fintech providers to create modular and flexible rules<br />

engines that ensure prices delivered to clients are up to<br />

date and in line with compliance needs.<br />

“We have been working with them to rethink our<br />

approach and processes in FX, but are also beginning<br />

to explore it in a cross-asset way (in particular Fixed<br />

Income),” Hutchinson says. “I think one of the hallmarks<br />

of the new world we find ourselves in is the concept of<br />

loosely coupled architecture. Older models were tightly<br />

coupled and created an oil tanker that couldn’t move.”<br />

As subsea cables from Meta and Google continue to<br />

boost digital adoption, the institutional fintech scene<br />

is witnessing interesting developments. “Africa’s young<br />

population has more access to technology than ever<br />

before,” 360T’s Tolmay says. “This is resulting in greater<br />

tech literacy making them more inclined to adopt digital<br />

services from banks. Digital FX services form part of a<br />

greater client offering that banks are in a race to provide<br />

their clients.”<br />

RMB’s Hutchinson details an interesting use case<br />

involving pre-trade rules engines. “One of my focuses<br />

at RMB has been delivering higher consistency in our<br />

direct-to-customer services,” he says. “Whether it’s a<br />

“The ability to connect to a third party service by API is a<br />

powerful piece of how we’re thinking of our architecture,”<br />

he says. When asked about how fintech fits into this<br />

puzzle, given its lack of knowledge about internal<br />

processes and compliance needs, Hutchinson explains that<br />

fintech is a part of the workflow, not all of it.<br />

“We’ve configured our rules and connected everything<br />

to our pricing engine,” he says. “We can then send<br />

a call to this third party engine that delivers a yes/no<br />

decision based on the conditions we’ve given it. This has<br />

been a powerful move for us and this is how we see our<br />

pre-trade rules working.”<br />

This move from a B2C orientation to an institutional one<br />

is highly encouraging in fintech circles. As technology<br />

adoption increases in the buy and sell side, fintech will<br />

likely make stronger appearances, leading to even more<br />

interesting use cases.<br />

JANUARY <strong>2024</strong> e-FOREX 35


CBP: A versatile and powerful<br />

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payments solutions<br />

We asked Chris Gibson, Director of Payments at smartTrade Technologies,<br />

to tell us more about his firm’s new class-leading FX and payments<br />

platform.<br />

PRODUCT REVIEW<br />

Chris Gibson<br />

Who are you targeting with<br />

Commercial Banking & Payments<br />

(CBP) and is likely to benefit most<br />

from deploying it?<br />

Of course, the name Commercial<br />

Banking & Payments suggests the<br />

most prominent target audience for<br />

the platform: financial institutions<br />

providing cross-border payments with<br />

FX to business clients. However, the<br />

strength of CBP goes beyond this<br />

single–albeit crucial–use case: it is<br />

an unrivaled FX distribution platform<br />

that allows banks to source, price,<br />

and distribute FX into any channel<br />

for any audience and need. Any bank<br />

or institution with a significant FX<br />

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not–can benefit from CBP.<br />

CBP unites FX and Payments<br />

capabilities in a single, powerful<br />

platform covering the entire FX<br />

and payments lifecycle. What are<br />

the advantages of doing that?<br />

Most FX clients today don’t have<br />

access to a platform that can provide<br />

adequate FX capabilities alongside<br />

the cash management and payments<br />

features that normally give rise to FX<br />

needs. This forces clients to spread<br />

their transactions across platforms and<br />

providers or to simply choose lesser FX<br />

solutions–or even none at all because<br />

the costs and risks of piecing together<br />

transactions across multiple venues<br />

are too high. Breaking what most<br />

clients see as a single transaction into<br />

multiple parts is both a loss of volume<br />

and an invitation to attrition. A single<br />

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What key features and<br />

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CBP covers the entire FX lifecycle<br />

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audiences with tailored pricing. Users<br />

can settle and fund FX transactions<br />

via any payment type and choose<br />

split, bulk, or post-dated payments.<br />

Cash management features include<br />

user roles, confirmations, netting,<br />

templates, and payment and<br />

instruction approvals. Controls include<br />

credit and deposit checks, risk and<br />

settlement limits, bank approval<br />

workflows, field validations and a<br />

range of other features that ensure<br />

transaction and platform integrity.<br />

In addition, CBP is fully ISO-20022<br />

compliant and can not only operate<br />

in both MX and MT formats but it<br />

can facilitate the transition to ISO<br />

compliance.<br />

How have you designed the<br />

platform to make it more intuitive<br />

and easy to use for clients and<br />

their staff?<br />

A key challenge for platforms<br />

incorporating payments and FX is<br />

enabling users to transact on familiar<br />

terms whether those terms are<br />

payments, FX, simple, or complex. CBP<br />

provides FX, payments, and combined<br />

workflows for straightforward to<br />

sophisticated users within a single<br />

interface. Banks can not only provide a<br />

natural payments or FX experience to<br />

their clients but they can also graduate<br />

those users to more sophisticated<br />

and higher-value transactions and<br />

36 JANUARY <strong>2024</strong> e-FOREX


PRODUCT REVIEW<br />

CBP Client Web with FX and Payments functionality for a sophisticated Commercial client<br />

deepen engagement with the bank.<br />

With Settlement Streaming, users can<br />

enter into transactions from either a<br />

settlement or FX perspective–whatever<br />

is more comfortable for them.<br />

How much flexibility does the<br />

platform provide for users who<br />

may have differing requirements?<br />

For example in dealing with<br />

multiple audiences or wanting to<br />

choose their own FX and Payments<br />

processing partners.<br />

The CBP platform is happily<br />

agnostic about liquidity sources,<br />

correspondents, and payment types.<br />

This allows a bank to assemble any<br />

combination of these and plug them<br />

into CBP to deliver the desired client<br />

experience. CBP’s smart routing<br />

capabilities allow it to select FX<br />

liquidity and deliver payments to<br />

particular providers based on a variety<br />

of criteria from currency, destination,<br />

transaction amount, or even payment<br />

cost.<br />

In a similar vein, CBP can serve<br />

different transactions, pricing,<br />

currencies, languages, and experiences<br />

to different customer types,<br />

geographies, languages, and even<br />

individual users. This allows a bank to<br />

provide a tailored FX and payments<br />

experience to multiple and different<br />

user groups on a single platform<br />

managed centrally.<br />

How easy is it to integrate CBP into<br />

existing legacy infrastructures?<br />

The CBP integration philosophy is<br />

best summed up as: capabilities<br />

without complexity. CBP’s cloud and<br />

API infrastructure connects not only<br />

with external venues such as LPs and<br />

correspondents but it also connects<br />

with bank infrastructure old and new.<br />

Deposit, credit, KYC, payments, and<br />

other systems can be accessed like<br />

services. Transactions and data pass<br />

and synchronize between the various<br />

platforms natively and securely.<br />

The CBP API suite can deliver the<br />

complete functionality of the<br />

platform and any connected LPs and<br />

correspondents. These capabilities can<br />

also be delivered directly into bank<br />

APIs (or other connectivity) and, of<br />

course, via the robust Client Web and<br />

Bank Trader interfaces.<br />

How can readers find out more<br />

about CBP?<br />

For detailed information on CBP, visit<br />

smart-trade.net/cbp/ or contact a<br />

smartTrade sales representative via our<br />

‘Contact Us’ page at smart-trade.net/<br />

contact-us/<br />

JANUARY <strong>2024</strong> e-FOREX 37


LMAX GLOBAL:<br />

Talking about a market leading firm that’s<br />

building an increasingly successful and<br />

diversified offering<br />

THE E-FOREX INTERVIEW<br />

Andreas Wigström<br />

38 JANUARY <strong>2024</strong> e-FOREX


THE e-FOREX INTERVIEW<br />

LMAX Group is a leading independent operator of multiple execution venues for FX and digital<br />

assets trading. e-<strong>Forex</strong> spoke to Andreas Wigström, Managing Director of LMAX Global, the<br />

company’s regulated broker, which offers retail brokers and professional traders around the<br />

world access to trade over 100 instruments including FX, metals, equity indices, commodities<br />

and crypto CFDs.<br />

Andreas, you joined LMAX Group<br />

in 2010 and are now Managing<br />

Director of LMAX Global. Please<br />

remind us how LMAX Global fits<br />

into the overall LMAX Group<br />

structure and the range of<br />

products and services each part of<br />

the business provides.<br />

LMAX Group is unique in offering fair<br />

and transparent global market access<br />

to all institutional customer segments,<br />

including banks, non-banks, the<br />

buy-side, and retail brokers. We have<br />

over 250 people working within the<br />

business across 11 offices worldwide<br />

and are continuously growing and<br />

expanding the business. We have<br />

a solid presence in all the major FX<br />

markets around the world, including<br />

Europe, North America, and Asia<br />

Pacific.<br />

Our rapidly expanding global<br />

institutional and professional client<br />

base is a testament to our distinctive,<br />

integrated business model, which<br />

delivers efficient market structure<br />

and transparent, precise, consistent<br />

execution to all market participants.<br />

Our business consists of three core<br />

entities: LMAX Exchange, which<br />

operates institutional FX exchanges,<br />

an FCA regulated MTF, and a MAS<br />

regulated RMO, LMAX Digital, a GFSC<br />

regulated institutional spot crypto<br />

currency exchange and custodian, and<br />

LMAX Global, which I lead, an FCA<br />

and CySec regulated broker for FX,<br />

metals, and commodities worldwide.<br />

What do your day-to-day<br />

responsibilities usually involve?<br />

I’m responsible for managing our<br />

teams around the world driving<br />

growth, expansion and overseeing<br />

sales coverage globally for LMAX<br />

Global. We operate FX brokers in the<br />

UK, Europe, and New Zealand and<br />

with liquidity pools in London, New<br />

York, Tokyo, and Singapore - it is a truly<br />

global role and requires me to conduct<br />

business at any time, on any given day.<br />

We have a solid presence in all the major FX markets around the world, including Europe, North America, and Asia Pacific<br />

JANUARY <strong>2024</strong> e-FOREX 39


LMAX Global: Talking about a market leading firm that’s building an increasingly successful and diversified offering<br />

THE E-FOREX INTERVIEW<br />

I spend a substantial portion of my<br />

time on the road, meeting with our<br />

clients to really understand their needs<br />

in terms of product demand. The<br />

beauty of our integrated exchangebroker<br />

model allows us to offer<br />

solutions to our clients according<br />

to their trading requirements. It’s<br />

an embodiment of our belief in fair<br />

market access for all, regardless of size,<br />

geography, or trading volume.<br />

As a team, we also participate in<br />

industry expos and events that bring<br />

together the key market participants<br />

including liquidity providers, banks,<br />

and regulators.<br />

Can you please tell us more about<br />

your integrated exchange-broker<br />

model and the types of clients you<br />

are providing for?<br />

Our integrated exchange-broker<br />

model offers LMAX Global clients<br />

access to trade on LMAX Exchange<br />

central limit order book and peer-topeer<br />

institutional liquidity. Enabling<br />

transparent price discovery and<br />

precise, consistent execution with no<br />

‘last look’ rejections.. Those global<br />

clients include broker dealers, money<br />

managers, MT4/5 brokers, and<br />

professional traders.<br />

It’s an institutional grade experience<br />

for clients that may not have previously<br />

has institutional grade access to<br />

the FX market. Similarly, in 2018<br />

we established LMAX Digital, our<br />

institutional crypto currency exchange<br />

in response to demand from clients<br />

for an institutional-grade experience<br />

in the digital assets market. Through<br />

this model, LMAX Global clients can<br />

seamlessly trade both spot FX and spot<br />

crypto currencies through the same<br />

trusted partner.<br />

Our clients have access to our global<br />

liquidity pools in London, New York,<br />

Tokyo, and Singapore and can trade<br />

over 100 instruments across FX,<br />

metals, equity indices, commodities<br />

and crypto CFDs.<br />

What makes LMAX Global<br />

different from many other firms<br />

operating in this market and its<br />

value proposition so attractive<br />

and unique? What are the key<br />

advantages of your central limit<br />

order book model?<br />

LMAX Global delivers the unique<br />

benefits of exchange quality execution,<br />

transparent price discovery and a<br />

level playing field for all brokers and<br />

professional traders.<br />

For brokers, money managers and<br />

professional traders, a central limit<br />

order book (CLOB) model offers<br />

streaming firm limit order liquidity<br />

from top tier banks and non-bank<br />

institutions, transparent price discovery<br />

and no ‘last look’ rejections, giving<br />

institutions full transparency of market<br />

dynamics and control over their<br />

execution strategy and costs.<br />

Our success reflects the genuine shift<br />

that the industry has undergone.<br />

We offer a unique integrated exchange-broker model which allows us to serve clients exactly where their needs are<br />

40 JANUARY <strong>2024</strong> e-FOREX


THE e-FOREX INTERVIEW<br />

Our clients have access to our global liquidity pools and can trade over 100 instruments across FX, metals, equity indices, commodities and crypto CFDs<br />

Clients from all FX market segments<br />

are trading increasingly more on orderdriven<br />

firm liquidity and requiring<br />

transparent, precise, and consistent<br />

execution.<br />

LMAX Group has always been well<br />

known for its marketing leading<br />

proprietary technology. How<br />

important is technology for your<br />

side of the business and how do<br />

you go about sourcing, operating,<br />

and leveraging it?<br />

From the outset, we knew that the<br />

only way to deliver precise, consistent,<br />

and reliable performance on our<br />

exchanges was to take a proprietary<br />

approach and build all our ultra-highperformance<br />

technology ourselves.<br />

This technology allows us to deliver<br />

an exceptional client experience<br />

24/7, but also means we can bring<br />

new innovations to the market and<br />

build new functionality quickly and<br />

seamlessly.<br />

We continuously focus our expertise<br />

on refining and improving all aspects<br />

of our technology. Our revolutionary<br />

and minimalist approach to<br />

architecture and technology-related<br />

processes are a careful blend of inhouse<br />

intellectual property and the<br />

most up-to-date best practice, with<br />

one aim in mind – optimised execution<br />

quality with superior ultra-low latency.<br />

In the past you have talked about<br />

not just offering better access and<br />

creating a level playing field for all<br />

participants but also changing the<br />

shape of that playing field. What<br />

did you mean by that?<br />

We offer an institutional-grade experience for clients that may not have previously had institutional-grade access<br />

to the FX market<br />

Our mission is to Build Fairer Markets<br />

for all and the leading cross-asset<br />

marketplace - something that we work<br />

towards and stand by daily within the<br />

business. Fairer markets are about<br />

creating more efficient markets with<br />

JANUARY <strong>2024</strong> e-FOREX 41


LMAX Global: Talking about a market leading firm that’s building an increasingly successful and diversified offering<br />

unlocking exciting possibilities. LMAX<br />

Group is well placed to take advantage<br />

of these opportunities.<br />

Who are the key members of<br />

your executive team and what<br />

roles do they each play within the<br />

company?<br />

We have a brilliant pool of talent<br />

within LMAX Group, and subsequently<br />

within LMAX Global.<br />

THE E-FOREX INTERVIEW<br />

We continuously focus our expertise on refining and improving all aspects of our technology<br />

access for all and that means not only solutions and believe that blockchain<br />

levelling out the playing field but also technology will form the backbone<br />

changing the shape of the playing of the capital markets of the future,<br />

field too. This involves breaking down solving many of the challenges<br />

previous industry conventions, setting experienced today. For example,<br />

improved standards and bringing new blockchain technology provides an<br />

practices to the market that better immutable and auditable record of<br />

serve the needs of our clients across transactions, eliminating the need for<br />

geographies and market segments. intermediaries to verify and reconcile<br />

records. This transparency reduces<br />

Challenging convention and counterparty risk and enhances market<br />

constantly looking for innovation integrity.<br />

seem to be part of the DNA<br />

of LMAX Group. What would The automation and efficiency offered<br />

you like to see to improve the by this technology has the potential to<br />

current structure and operating streamline capital markets processes.<br />

characteristics of the markets in Smart contracts automate the execution<br />

which you are doing business? of agreements, reducing manual errors<br />

and operational costs. As a result,<br />

LMAX Group is one of the few<br />

capital market participants can enjoy<br />

companies in the market which is lower fees, faster liquidity, and improved<br />

bilingual and excels in both traditional operational efficiency, driving growth.<br />

trading, credit, and settlement and<br />

blockchain. We are leveraging our The convergence of traditional finance<br />

footprint in traditional finance and and DeFi presents immense potential<br />

tokenisation to educate and create for the future of capital markets,<br />

I am supported day-to-day by<br />

our compliance, client services,<br />

operations, and regional sales teams.<br />

Critical to the business are also<br />

several technology specialists and<br />

developers who are continuously<br />

refining and improving all aspects<br />

of our technology and exchange<br />

infrastructure.<br />

Within LMAX Group we have a very<br />

adaptable and agile global team, and<br />

therefore access to pools of talent and<br />

expertise across the broader business<br />

functions as required, depending on<br />

our client needs.<br />

What is the LMAX Global team<br />

currently doing to explore and<br />

develop new products and services<br />

to cater for the evolving needs of<br />

your clients?<br />

We are part of a regulated business<br />

which has a unique proposition<br />

enabled by our robust scalable<br />

technology and global exchange<br />

footprint. Our unique exchange-broker<br />

integrated business model allows us<br />

to service clients across all market<br />

segments and offer them opportunities<br />

to trade in both traditional and digital<br />

assets, through the combination of our<br />

LMAX Exchange, LMAX Digital and<br />

broker businesses. That’s a powerful<br />

combination.<br />

Most recently, we received our<br />

Recognised Market Operator (RMO)<br />

42 JANUARY <strong>2024</strong> e-FOREX


THE e-FOREX INTERVIEW<br />

Licence from the Monetary Authority<br />

of Singapore enabling LMAX Exchange<br />

to offer Non-Deliverable Forward (NDF)<br />

trading in Singapore and London. We<br />

are building an increasingly diversified<br />

offering in Asia Pacific to support<br />

growing demand from institutional<br />

investors operating in the region.<br />

We see significant potential to develop<br />

our global footprint, especially as the<br />

convergence between crypto and<br />

traditional capital markets continues<br />

apace. Ultimately, we see a major<br />

opportunity to offer FX and crypto<br />

trading via one exchange – we<br />

continuously look to rethink market<br />

structures and challenge the status<br />

quo.<br />

You have a great deal of<br />

experience in Asia having<br />

previously helped to drive the<br />

business growth of LMAX Group<br />

across that region. How important<br />

will this part of world be for LMAX<br />

Global over the next few years?<br />

The APAC region is particularly<br />

important for the growth of LMAX<br />

Global. We’ve been operating a local<br />

exchange in Tokyo since 2014. We<br />

have a fantastic institutional clientbase<br />

made up of Tier 1 brokers,<br />

local banks, and proprietary trading<br />

firms and increasingly we’re seeing<br />

participation from global as well as<br />

local institutions.<br />

For brokers, money managers and professional traders, a central limit order book (CLOB) model offers many<br />

advantages<br />

What do you enjoy most about<br />

the work you do and the office<br />

environment?<br />

As an independent exchange operator,<br />

we’re able to innovate, optimise and<br />

roll-out new products more efficiently<br />

to serve our global institutional and<br />

professional client base across the<br />

Group. It also helps to be surrounded<br />

by super smart people who like<br />

to challenge convention and are<br />

We opened our regional hub in<br />

Singapore in June 2015 and set-up<br />

our matching engine there in 2022<br />

which has gained significant traction<br />

locally and has a strong pipeline of<br />

institutional customers looking to<br />

onboard adding significant value for<br />

the local financial eco-system. We see<br />

further potential to enhance market<br />

access to this institutional liquidity by<br />

establishing an Asia Pacific corridor<br />

between our twin hubs in Tokyo (TY3)<br />

and Singapore (SG1).<br />

We are of the opinion that market data is becoming increasingly important within the industry<br />

JANUARY <strong>2024</strong> e-FOREX 43


LMAX Global: Talking about a market leading firm that’s building an increasingly successful and diversified offering<br />

constantly exploring innovation. That’s<br />

very much the case at LMAX Group.<br />

In terms of our environment, we’ve<br />

just recently completely renovated<br />

our offices in London, New York, and<br />

Singapore, unveiling collaborative<br />

spaces that better reflect the business<br />

we are today. It has refreshed our<br />

behaviors, mindset and energy and<br />

we’re ready to take on the years<br />

ahead.<br />

What are going to be your<br />

priorities this year as you and your<br />

team work to grow the business<br />

further and maintain its market<br />

leading position?<br />

THE E-FOREX INTERVIEW<br />

We’ve just recently completely renovated our offices in London, New York, and Singapore<br />

We continue to invest in our<br />

distribution capabilities and<br />

infrastructure globally and deepen our<br />

client relationships across the globe.<br />

Our ongoing technology investment<br />

has ensured resilience, security, and<br />

increased capacity of our exchanges.<br />

We are of the opinion that market data<br />

is becoming increasingly important<br />

within the industry, as businesses such<br />

as ours and the other major players<br />

in the market seek to capitalise on<br />

its availability and potential. The fact<br />

that we gather firm liquidity market<br />

data from all client segments, often<br />

not accessible through primary<br />

venues, puts us in a differentiated and<br />

advantageous position compared to<br />

others.<br />

Our ability to provide true price<br />

discovery and liquidity from all market<br />

segments means that we can capture<br />

greater insights that help our clients.<br />

The Group is well positioned to lead<br />

in both FX and digital assets due<br />

to our unique and complementary<br />

triangulation of brands, enabling us to<br />

overcome industry infrastructure gaps<br />

and cross-sell to our global institutional<br />

client base.<br />

44 JANUARY <strong>2024</strong> e-FOREX


THE e-FOREX INTERVIEW<br />

WE SEE SIGNIFICANT<br />

POTENTIAL TO DEVELOP<br />

OUR GLOBAL FOOTPRINT,<br />

ESPECIALLY AS THE<br />

CONVERGENCE BETWEEN<br />

CRYPTO AND TRADITIONAL<br />

CAPITAL MARKETS<br />

CONTINUES APACE<br />

JANUARY <strong>2024</strong> e-FOREX 45


NDFs: The market looks<br />

towards increasing<br />

electronification to meet<br />

rising demand<br />

As the demand for NDFs continue to surge, Nicholas Pratt examines<br />

the role of electronic trading and technology to meet this<br />

SPECIAL REPORT<br />

Image by Shutterstock<br />

46 JANUARY <strong>2024</strong> e-FOREX


SPECIAL REPORT<br />

Nicholas Pratt<br />

The NDF market enjoyed a huge surge<br />

in demand between 2016 and 2019<br />

when, according to the BIS Triennial<br />

Survey of 2019, average daily volumes<br />

more than doubled, from $127 billion<br />

to $258 billion. The acceleration slowed<br />

somewhat in the BIS survey of 2022<br />

with average daily volumes reaching<br />

$266 billion.<br />

Yet demand remains high, particularly<br />

in emerging markets, driven by a<br />

confluence of factors. Chief among<br />

these is the ongoing globalisation of<br />

financial markets as investors allocate<br />

more assets to emerging markets in the<br />

face of slowing economies in developed<br />

markets. This has fueled the need for<br />

hedging against currency risk, within<br />

which NDFs can play a critical role.<br />

The electronification of local market<br />

makers has also helped to meet the<br />

demand for NDF trading by increasing<br />

the access to NDF pricing and reliable<br />

sources of liquidity, as have some<br />

regulatory tailwinds that have helped<br />

to promote a more diverse market<br />

for product development. But more<br />

investment in electronic trading services<br />

will be needed if the NDF market is to<br />

reach its potential.<br />

Due to differences in FX volatility<br />

between developed and emerging<br />

markets, asset owners are often<br />

reallocating risk to EM countries. And<br />

because many of the currencies in<br />

these countries are still non-convertible,<br />

the typical way for offshore investors to<br />

trade in those markets is via NDFs. “Asia<br />

in particular accounts for four of the<br />

top five traded NDF currencies globally<br />

based on the BIS survey including large<br />

manufacturing-based economies like<br />

China, South Korea and India,” says<br />

Oleg Shevelenko, FX Product Manager<br />

at Bloomberg.<br />

While NDF markets are typically used to<br />

hedge FX exposures often linked to fixed<br />

income holdings, speculative trading<br />

is also on the rise, says Shevelenko,<br />

which is generally a reflection of<br />

market growth and sophistication.<br />

“In most cases, NDFs have higher<br />

volumes than their deliverable onshore<br />

currency equivalents due to a wider<br />

group of market participants and<br />

recent technological advances in the<br />

NDF markets such as locally hosted<br />

order books and the rise of algorithmic<br />

trading,” says Shevelenko. “The fact<br />

that the NDF market is a part of global<br />

derivatives reform and as such is subject<br />

to clear regulatory trading and reporting<br />

standards removes various regulatory<br />

concerns and opens wider investment<br />

opportunities.”<br />

JANUARY <strong>2024</strong> e-FOREX 47


NDFs: The market looks towards increasing electronification to meet rising demand<br />

“As we learned from the spot market, the introduction of algo<br />

execution itself brings efficiency, consistency of pricing, and<br />

standardization to the market which creates a ripple effect for<br />

further algo adoption. We are starting to observe the same<br />

with NDFs,”<br />

asset and take additional execution<br />

responsibilities, voice execution ceases<br />

to be a viable option due to the time it<br />

takes to analyse, execute and book the<br />

trade.”<br />

While NDF algos are being offered<br />

SPECIAL REPORT<br />

Oleg Shevelenko<br />

NEW ELECTRONIC SERVICES<br />

As a consequence of the surging NDF<br />

demand, FX providers are launching<br />

new electronic trading and clearing<br />

services for these instruments. In 2023,<br />

FXGO, Bloomberg’s multibank FX<br />

trading platform, launched a regional<br />

hosting service in Singapore for its<br />

Asia Pacific clients designed to improve<br />

transparency and pricing for local<br />

markets. FXGO also hosts a number<br />

of regional banks’ algos. “Despite<br />

the absence of a clearing mandate, a<br />

proportion of NDFs is being centrally<br />

cleared,” says Shevelenko. “This helps<br />

reduce the cost of capital, counterparty<br />

risk and improves market efficiency,<br />

contributing to the overall growth of<br />

NDFs.”<br />

There has also been some work done<br />

to improve the fragile liquidity of the<br />

NDF market, says Shevelenko. “Industry<br />

surveys continue to highlight that NDF<br />

turnover in aggregate is on the rise.<br />

For example, the Bank of England<br />

reported record highs for NDF turnover<br />

in its latest semi-annual FX turnover<br />

survey, with a 4% increase. However,<br />

the paths of each NDF currency are<br />

very different. Some emerging market<br />

countries embrace and support the<br />

growth of their existing NDF markets<br />

allowing local investors to participate<br />

directly or indirectly, while the others<br />

carefully regulate and restrict access to<br />

it. In addition, the internationalization<br />

of China’s renminbi resulted in the<br />

rapid growth of the deliverable forward<br />

CNH market as an alternative to NDFs.<br />

FXGO deployed its trade negotiations<br />

and analytics tools in various emerging<br />

markets to help participants optimize<br />

access to both onshore and NDF<br />

liquidity via RFQ, auctions, streaming,<br />

central limit order book and algorithmic<br />

orders.”<br />

There is still more work to be done<br />

though, says Shevelenko. “Although<br />

still in early stages, in many regards<br />

the path to the electronification of<br />

NDFs resembles the one for FX spot.<br />

Leading market makers and electronic<br />

trading platforms started with<br />

electronic pricing of NDFs which in turn<br />

enabled automated hedging and risk<br />

management. As automated hedging<br />

is a key operational requirement for<br />

algorithms, market makers are now<br />

able to offer basic NDF algos to their<br />

clients to leverage.”<br />

Despite those recent advances, many<br />

NDF markets still operate on a very<br />

thin liquidity especially outside of local<br />

market hours, says Shevelenko. “Due<br />

to the bilateral nature of FX markets,<br />

participants don’t always have access to<br />

the local liquidity providers, especially<br />

as NDFs are derivatives compared to<br />

spot. A more widespread adoption<br />

of FX clearing is likely to bring more<br />

market participants together and<br />

facilitate further market growth. Finally,<br />

as buy-side desks are becoming multi-<br />

by the major liquidity providers and<br />

being actively evaluated by the buyside,<br />

there are still several challenges<br />

prior to meaningful adoption, says<br />

Shevelenko. “For example, the number<br />

of venues offering electronic trading<br />

of NDFs is still limited. Liquidity is<br />

inconsistent and nuanced across NDF<br />

pairs. Algorithms themselves are not<br />

as proven and well-defined as for spot.<br />

Some buy-side firms don’t have reliable<br />

access to market data to trigger the<br />

algo. On the bright side, as we learned<br />

from the spot market, the introduction<br />

of algo execution itself brings<br />

efficiency, consistency of pricing, and<br />

standardization to the market which<br />

creates a ripple effect for further algo<br />

adoption. We are starting to observe<br />

the same with NDFs.”<br />

And what of the future growth<br />

prospects for NDFs? “Due to the<br />

rapid growth of various emerging<br />

market economies, asset managers<br />

are likely to continue to increase their<br />

asset allocation in respective markets<br />

which will drive the usage of NDFs as<br />

a hedging tool,” says Shevelenko. “In<br />

response, electronic trading capabilities<br />

of NDFs including trading on regulated<br />

venues (SEFs and MTFs), accessing<br />

streaming liquidity and the usage of<br />

NDF algos will continue to evolve.<br />

The industry will need to settle on<br />

the clearing debate which will largely<br />

depend on whether the FX clearing<br />

framework can be expanded beyond<br />

NDFs. Finally, bank and non-bank<br />

liquidity providers as well as multi-bank<br />

venues would need to work together<br />

on standardizing access to liquidity,<br />

workflows and post-trade clearing and<br />

settlement practices to match what is<br />

currently available in FX spot.”<br />

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JANUARY <strong>2024</strong> e-FOREX 49


NDFs: The market looks towards increasing electronification to meet rising demand<br />

SPECIAL REPORT<br />

“As technology continues to evolve, onshore participation<br />

will continue to improve, utilizing tools and infrastructure<br />

to seamlessly engage in NDF trading, enhancing market<br />

accessibility, liquidity and transparency,”<br />

Brian Andreyko<br />

SOLUTIONS TAILORED TO NDFS<br />

As the demand for NDFs undergoes<br />

rapid upswing in adoption, due in part<br />

to large swings in country interest rate<br />

differentials, leading FX providers are<br />

strategically responding by introducing<br />

innovative electronic trading products<br />

and clearing services, tailored<br />

specifically for these instruments.<br />

“At Edgewater, we have been<br />

providing solutions to onshore<br />

institutions that enable them to<br />

embrace electronification and scale<br />

their operations to meet the growing<br />

global demand for NDFs,” says Brian<br />

Andreyko, chief product officer at<br />

Edgewater Markets, the US-based<br />

FX trading technology provider. “By<br />

offering electronic trading platforms<br />

and tools, onshore institutions can not<br />

only compete, but thrive in servicing<br />

the global marketplace. This enhances<br />

overall market efficiency while reducing<br />

operational complexities. This increases<br />

profitability of onshore participants<br />

and adds a new and expanded global<br />

client base, capitalizing on datadriven<br />

optimized trading. This strategic<br />

approach aligns with the broader trend<br />

of technology-driven transformations<br />

of other financial markets, compressing<br />

spreads and costs for clients, and<br />

matching global client interest with<br />

onshore market inventory.”<br />

But in emerging markets, technology<br />

is not enough, he says. “Leading FX<br />

providers are also introducing credit<br />

intermediation services that cater<br />

to global distribution. Edgewater<br />

recognizes the global nature of NDF<br />

trading, and the diverse array of<br />

participants and counties involved.<br />

Offering credit intermediation solutions<br />

that broaden trading relationship<br />

become paramount, particularly in<br />

To facilitate further electronification we would need larger adoption of e-FX solutions from tier 2/3 banks in<br />

emerging markets<br />

emerging markets where credit is<br />

restrictive. For example, at Edgewater,<br />

through a single credit clearing<br />

relationship with one of our global<br />

Prime Brokers, we connect our clients<br />

to multiple onshore participants in<br />

multiple countries, eliminating the<br />

need for global participants to set<br />

up hundreds of ISDAs with individual<br />

onshore providers. Bridging the credit<br />

gap between Edgewater’s clients<br />

and onshore liquidity partners has<br />

significantly enhanced overall liquidity<br />

and accessibility of NDF markets.”<br />

A significant role played by service<br />

providers involves credit intermediation,<br />

says Andreyko. “By leveraging the<br />

services of third-party intermediaries,<br />

market participants can access a<br />

broader pool of liquidity providers.<br />

This approach helps alleviate liquidity<br />

constraints by connecting buyers with<br />

an array of sellers, fostering a more<br />

dynamic, interconnected, and efficient<br />

marketplace. Edgewater’s credit<br />

intermediation services are one of the<br />

most robust and compelling parts of<br />

our offering that enhances NDF trading<br />

for all participants involved.”<br />

Furthermore, there has been a strategic<br />

shift in bank workflows to capitalize on<br />

increasing global market demand, says<br />

Andreyko. “This adaptation involves<br />

optimizing internal bank processes<br />

that allow them to scale and better<br />

service not only their existing onshore<br />

business, but global NDF demand<br />

as well. By aligning workflows with<br />

credit resources, market participants<br />

direct flows to those that specialize<br />

in a particular currency, fostering<br />

a more stable and resilient trading<br />

environment. At Edgewater, our<br />

liquidity partners tell us often how<br />

transformative their business has<br />

become with our global distribution<br />

abilities comingled with our credit<br />

intermediation and technology<br />

services.”<br />

50 JANUARY <strong>2024</strong> e-FOREX


JANUARY <strong>2024</strong> e-FOREX 51


NDFs: The market looks towards increasing electronification to meet rising demand<br />

SPECIAL REPORT<br />

To facilitate further electronification,<br />

there is a need for continued<br />

development and adoption of various<br />

trading methodologies alongside global<br />

connectivity solutions that match<br />

onshore and offshore participants, says<br />

Andreyko. “Specifically, our clients are<br />

looking for solutions that address larger<br />

trade sizes with the efficiency that<br />

electronification offers. To provide this,<br />

Edgewater has recently implemented<br />

anonymous Request for Quote (RFQ)<br />

trading, incorporating technology that<br />

emulates voice driven markets while<br />

providing the efficiency and scale of<br />

electronic trading. This development<br />

has expanded trade flow, allowing<br />

firms to source competitive pricing and<br />

execute trades more efficiently and cost<br />

effectively, eliminating middlemen. This<br />

interaction is instrumental in building<br />

trust among market participants,<br />

ultimately fostering increased<br />

participation and liquidity.”<br />

One notable challenge of delivering<br />

NDF algos is the requirement for the<br />

algo to interact with liquidity providers<br />

that have deep enough books of<br />

business to warehouse the transaction<br />

flow, says Andreyko. “To address this<br />

challenge, collaboration with onshore<br />

banks becomes crucial. Onshore banks,<br />

equipped with warehouse capabilities<br />

broadened by their onshore flow,<br />

can play a pivotal role in improving<br />

NDF algo performance that has been<br />

lacking. By leveraging electronic access<br />

and risk management expertise of<br />

onshore banks, NDF algorithms can<br />

expand their scope and effectiveness,<br />

while reducing market impact,<br />

an inherent risk associated with<br />

algorithmic trading performance,” he<br />

says.<br />

The future outlook is promising, with<br />

several factors contributing to NDFs<br />

continued expansion, says Andreyko.<br />

“The continued development in arming<br />

onshore participants with technology<br />

to participate in global markets is<br />

paramount. As technology continues<br />

to evolve, onshore participation will<br />

continue to expand and improve,<br />

utilizing tools and infrastructure to<br />

seamlessly engage in NDF trading,<br />

enhancing market accessibility,<br />

liquidity and transparency. This will<br />

significantly contribute to the overall<br />

growth and vibrancy of NDF markets,<br />

providing geographical diversification<br />

that unlocks new opportunities for<br />

participants, further fuelling the growth<br />

of NDFs on a global scale.”<br />

Additionally, the provision of credit<br />

intermediation services that enable<br />

onshore participants to participate in<br />

global markets is a crucial component,<br />

says Andreyko. “By facilitating secure<br />

and efficient global distribution and<br />

credit intermediation services, we<br />

bridge the gap between onshore<br />

and offshore markets. This not only<br />

enhances market inclusivity but<br />

also encourages a diverse range of<br />

participants to engage in NDF trading,<br />

further amplifying market liquidity and<br />

activity. Lastly, one significant trend<br />

is the ongoing discussions in many<br />

markets, including India, Korea, and<br />

Chile, regarding the eventual opening<br />

up of their currencies. The potential<br />

maturation of these new markets will<br />

first go through a robust period of NDF<br />

trading as these markets begin that<br />

transition.”<br />

IMPROVING LIQUIDITY<br />

The adoption of electronic trading<br />

platforms has played a significant<br />

role in improving liquidity in NDF<br />

markets, says Andrea Sanna, head of<br />

liquidity management at London-based<br />

institutional FX broker Alp Financial.<br />

“These platforms offer transparency,<br />

efficiency, and accessibility, attracting<br />

a broader range of participants.<br />

Moreover, regulatory authorities have<br />

been active in addressing liquidity<br />

issues and any regulatory barriers that<br />

hinder market liquidity,” says Sanna.<br />

“The increased capabilities of e-FX<br />

trading systems nowadays allow for<br />

much more advanced and tailored<br />

liquidity offerings. Current technology<br />

can handle with no difficulty pricing in<br />

NDFs according to several workflows<br />

such as RFQ, RFS, or Streaming to<br />

accommodate customer needs.<br />

THE ELECTRONIC<br />

TRADING CAPABILITIES<br />

OF NDFS INCLUDING<br />

TRADING ON<br />

REGULATED VENUES<br />

WILL CONTINUE TO<br />

EVOLVE<br />

Liquidity providers, both brokers and<br />

market makers, are adapting swiftly to<br />

structure their pricing models to this<br />

market that in the new future will see<br />

an increasing spillover effect from voice<br />

to electronic trading,” says Sanna.<br />

“Similarly, to what was observed<br />

in recent years in full amount autopricing<br />

the tendency to auto-price and<br />

auto-hedge risk coming from NDFs<br />

will gradually extend to tickets larger<br />

in size and to products that result less<br />

liquid as soon as models and liquidity<br />

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JANUARY <strong>2024</strong> e-FOREX 53


NDFs: The market looks towards increasing electronification to meet rising demand<br />

SPECIAL REPORT<br />

“The evolving landscape, influenced by factors such as<br />

ESG considerations, economic trends, and integration with<br />

traditional FX markets, will shape the trajectory of NDF<br />

markets, requiring ongoing collaboration among stakeholders<br />

for a resilient and efficient future.”<br />

Andrea Sanna<br />

pools migrate towards electronic<br />

marketplaces,” says Sanna. “The clarity<br />

of the regulatory environment plays<br />

a pivotal role in allowing brokers and<br />

market makers to get the necessary<br />

confidence to price more extensively<br />

NDFs on an electronic fashion.<br />

However, at AlpFin we do think that the<br />

process already started, we can see that<br />

with respect to Asian NDFs, and this<br />

tendency will extend gradually to other<br />

regions.”<br />

Facilitating further electronification<br />

within NDF markets involves<br />

addressing challenges such as market<br />

fragmentation, liquidity concerns,<br />

and regulatory considerations, says<br />

Sanna. “Improvements in technology<br />

infrastructure, standardized clearing<br />

processes, and enhanced market<br />

structures are key to fostering<br />

electronification. Achieving these<br />

improvements will create a more<br />

efficient environment for trading<br />

firms to thrive in electronic trading.<br />

To facilitate further electronification<br />

we would need larger adoption of<br />

e-FX Solutions from tier 2/3 banks in<br />

emerging markets; increased clarity<br />

on the regulatory front with respect<br />

to NDF products; and reduced capital<br />

and margin requirements for customers<br />

and LPs willing to trade these products.<br />

The improvement of these points<br />

will initiate a virtuous circle that will<br />

naturally bring improved liquidity,<br />

lower spreads, larger volumes, and<br />

standardized and less VaR intensive risk<br />

management protocols.”<br />

There are challenges involved in<br />

delivering more electronification to<br />

the NDF market though, says Sanna,<br />

especially when it comes to NDFspecific<br />

algos. “Although algos are<br />

a prerogative of banks and venues,<br />

one of the main challenges to offer<br />

algos in NDF is connectivity to end<br />

customers that would like to use them<br />

either via GUI or API. At the moment,<br />

the customers that would like to use<br />

this service either don’t have an e-FX<br />

Solution or they don’t have enough<br />

credit standing to get a prime broker<br />

that allows them to connect to Tier 1 or<br />

Tier 2 liquidity providers,” says Sanna.<br />

“Delivering NDF algos presents diverse<br />

challenges, including liquidity concerns,<br />

market fragmentation, volatility, data<br />

quality issues, regulatory compliance,<br />

and technological infrastructure<br />

limitations. To address these challenges,<br />

NDF algorithms are designed with<br />

features such as intelligent liquidity<br />

sourcing, risk management strategies,<br />

data processing capabilities, and<br />

compliance checks. Technological<br />

advancements will contribute to<br />

algorithmic adaptability to changing<br />

market conditions, and continuous<br />

collaboration among quantitative<br />

analysts, technologists, and<br />

compliance professionals is essential<br />

for the successful deployment of NDF<br />

algorithms,” says Sanna.<br />

The future of NDFs is poised for<br />

growth with potential developments<br />

in regulatory frameworks, trading<br />

technology, and market dynamics, says<br />

Sanna. He points to four developments<br />

that would help the NDF market grow<br />

further.<br />

• Larger adoption of e-FX solutions<br />

from tier 2/3 banks and buy-side takers<br />

and providers in the Sub-Saharan<br />

region together with Latin America<br />

• Clarification of the MiFID<br />

requirements for brokers to operate in<br />

the NDF space in emerging countries<br />

• Increased presence of venues that do<br />

offer streaming liquidity pools in South<br />

American and African NDFs<br />

• Increased liquidity that will underpin<br />

a decrease in clearing costs and reduce<br />

spreads.<br />

“The evolving landscape, influenced<br />

by factors such as ESG considerations,<br />

economic trends, and integration<br />

with traditional FX markets, will<br />

shape the trajectory of NDF markets,<br />

requiring ongoing collaboration among<br />

stakeholders for a resilient and efficient<br />

future,” adds Sanna.<br />

REGULATORY DRIVERS AND<br />

RELIABLE DATA<br />

Historically, the fragility of the NDF<br />

market is due to a lack of depth of<br />

liquidity in the market which can<br />

create gaps in directional trading, says<br />

Wyman Shing, sales director APAC at<br />

Euronext FX. “Also, there has been a<br />

lack of reliable market data to inform<br />

participants. Liquidity providers cannot<br />

price without knowing where the<br />

market is.”<br />

Regulators have also taken several steps<br />

to improve the fragility of NDF liquidity<br />

environment, says Shing. “Regulators<br />

have implemented capital and margin<br />

requirements to reduce counterparty risk<br />

and encourage more liquidity. They have<br />

also implemented a range of measures<br />

to encourage more transparency in the<br />

NDF market, such as the introduction<br />

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NDFs: The market looks towards increasing electronification to meet rising demand<br />

SPECIAL REPORT<br />

“As more financial institutions adopt electronic trading<br />

systems, the market for NDFs will become even more efficient<br />

and liquid, allowing for more competitive pricing and faster<br />

transactions,”<br />

Wyman Shing<br />

of standardized contracts and reporting<br />

requirements for trades. And they have<br />

worked to implement new regulatory<br />

frameworks to ensure a more stable<br />

and transparent environment for NDF<br />

trading.”<br />

In addition to regulatory action, the<br />

market itself has also adjusted and<br />

innovated to face the liquidity challenges<br />

in the NDF market, says Shing. “Market<br />

participants have developed a range of<br />

solutions to enhance liquidity in the NDF<br />

market. These include the introduction<br />

of a central limit order book and the<br />

use of algorithms to match buy and<br />

sell orders. Banks and other financial<br />

institutions have increased their presence<br />

in the NDF market by providing liquidity<br />

through their own trading desks. Market<br />

participants have also established several<br />

electronic trading platforms to facilitate<br />

trading in NDFs. These platforms provide<br />

access to a range of NDF currencies<br />

and have also reduced transaction<br />

costs. ECNs such as Euronext Markets<br />

Singapore have increased and improved<br />

access to quality liquidity at high speeds<br />

and increased transparency via more<br />

reliable market data. And local liquidity<br />

providers with access to uncorrelated<br />

flow have advanced their technology<br />

and now can participate in electronic<br />

markets directly.”<br />

WORK TO BE DONE<br />

In terms of what needs to be done<br />

to ensure further electronification of<br />

the NDF markets, Shing highlights five<br />

measures – increased automation,<br />

regulatory pressures, the need for<br />

cost savings, improved liquidity and<br />

improved access to data. “Automation<br />

has been a major factor in driving the<br />

further electronification of NDF markets.<br />

Automated trading systems have<br />

allowed trading firms to execute trades,<br />

reducing market impact and improving<br />

liquidity quickly and accurately,” says<br />

Shing.<br />

“Regulators around the world are<br />

increasingly pushing for greater<br />

transparency and efficiency in financial<br />

markets, which has been a major driver<br />

of electronification. By requiring firms<br />

to move to electronic trading systems,<br />

regulators hope to reduce market<br />

manipulation and improve market<br />

integrity,” says Shing. “By moving to<br />

electronic trading systems, trading firms<br />

can reduce costs associated with manual<br />

trading, such as the costs of hiring<br />

traders and administrative staff. This can<br />

lead to increased profitability for trading<br />

firms.”<br />

Electronic trading systems have made<br />

it easier for trading firms to find<br />

counterparties and execute trades, says<br />

Shing. “At Euronext Markets Singapore,<br />

we’ve seen increasing liquidity from Tier<br />

1 banks expanding their global reach<br />

as well as from local specialists as they<br />

embrace advancing technology. Electronic<br />

trading systems have also allowed<br />

trading firms to access real-time market<br />

data, allowing them to identify trading<br />

opportunities and make more informed<br />

decisions more quickly. This can lead to<br />

increased profits for trading firms.”<br />

The main challenge of delivering NDF<br />

algorithms is that they are complex and<br />

require a lot of data to be processed<br />

to accurately calculate the forward<br />

rate, says Shing. “Additionally, NDF<br />

algorithms can be sensitive to market<br />

conditions and changes in foreign<br />

exchange rates, which can make them<br />

difficult to implement. To improve upon<br />

these challenges, machine learning<br />

algorithms are being used to better<br />

predict the forward rate. Furthermore,<br />

NDF algorithms are being improved by<br />

incorporating more data points and<br />

creating more sophisticated models.<br />

This allows them to better account for<br />

potential shifts in the foreign exchange<br />

rate and react accordingly. Finally, the<br />

use of big data analytics and artificial<br />

intelligence is being used to further<br />

enhance the capabilities of NDF<br />

algorithms,” he states.<br />

As the global economy becomes<br />

increasingly interconnected, demand for<br />

NDFs will continue to grow, says Shing.<br />

“The continued growth of electronic<br />

trading platforms further strengthens<br />

the market for NDFs and makes them<br />

more accessible to a wider range of<br />

investors. Additionally, the development<br />

of automated pricing models, increased<br />

liquidity, and better price transparency<br />

will make NDFs even more attractive<br />

to both buyers and sellers. As more<br />

financial institutions adopt electronic<br />

trading systems, the market for NDFs<br />

will become even more efficient and<br />

liquid, allowing for more competitive<br />

pricing and faster transactions. As the<br />

market matures, more exotic currencies<br />

will become available, allowing market<br />

participants to access markets they may<br />

have previously been unable to access.<br />

All these developments will help to<br />

further unlock the potential of NDFs<br />

and make them an even more attractive<br />

financial option,” says Shing.<br />

56 JANUARY <strong>2024</strong> e-FOREX


NDF trading at<br />

Euronext Markets<br />

Singapore<br />

Euronext FX is a leading ECN for Spot FX and Precious<br />

Metals, as well as NDFs through its Singapore<br />

subsidiary Euronext Markets Singapore. Powered by<br />

award winning FastMatch ® technology, Euronext FX<br />

with Euronext Markets Singapore has matching engines<br />

in London, New York, Tokyo and Singapore. This bestin-class<br />

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Clients can trade FX NDFs through its subsidiary,<br />

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KEY FEATURES<br />

• Local NDF matching available in SG1 and LD4<br />

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• Customised liquidity pools: Including firm and last<br />

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and full amount, SkewSafe<br />

• Full range of order types including market and limit<br />

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• Unparalleled speed powered by award winning<br />

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• Clients of Euronext Markets Singapore may connect<br />

through our data centres in Singapore (SG1), New<br />

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• Connect via FIX API<br />

• Euronext Markets Singapore has been granted SEF<br />

equivalency by the CFTC<br />

• Protection variants including leak/sweep protection<br />

and full amount lock-in<br />

Euronext FX is a company of Euronext, the leading multi-asset and pan-European<br />

exchange with markets in Amsterdam, Brussels, Dublin, Lisbon, Oslo, Paris and Italy.<br />

sales_fx@euronext.com<br />

This publication is for information purposes only and is not a recommendation to engage in investment activities. This publication is provided “as is” without representation or warranty of any<br />

kind. Whilst all reasonable care has been taken to ensure the accuracy of the content, Euronext does not guarantee its accuracy or completeness. Euronext will not be held liable for any loss or<br />

damages of any nature ensuing from using, trusting or acting on information provided. No information set out or referred to in this publication shall form the basis of any contract. The creation<br />

of rights and obligations in respect of financial products that are traded on the exchanges operated by Euronext’s subsidiaries shall depend solely on the applicable rules of the market operator.<br />

All proprietary rights and interest in or connected with this publication shall vest in Euronext. No part of it may be redistributed or reproduced in any form without the prior written permission of<br />

Euronext. Euronext refers to Euronext N.V. and its affiliates.<br />

© 2023 Euronext N.V. – All rights reserved.<br />

JANUARY <strong>2024</strong> e-FOREX 57


The value of performance<br />

analysis and network monitoring<br />

solutions to the trading world<br />

Beeks Group outlines how a costly IPO sparked the genesis of<br />

Market Data Capture and Replay solution mdPlay<br />

EXPERT OPINION<br />

Following a period of subdued activity<br />

post-pandemic, the IPO markets are<br />

regaining momentum. Looking back<br />

at Alibaba’s record launch in 2014,<br />

valued at over $169 billion, we now<br />

find the company once again in the<br />

spotlight with the press reflecting<br />

on its prospects of taking two of<br />

its subsidiaries to IPO in <strong>2024</strong> and<br />

subsequent abrupt share price decline.<br />

IPOs are not straightforward. But the<br />

most pertinent risk for this piece is<br />

how IPO trading offers a gruelling test<br />

of Capital Markets’ participants’ IT<br />

infrastructure.<br />

THE IMPORTANCE OF<br />

PERFORMANCE ANALYSIS<br />

CEO of Capital Markets infrastructure<br />

specialist Beeks Group, Gordon<br />

McArthur clearly states: “IPO trading<br />

can be so busy that it can seriously<br />

expose weaknesses in a company’s<br />

data handling performance. Real-time<br />

data is crucial – and when real time<br />

is measured in nanosecond units you<br />

need to be able to capture, analyse<br />

and replay data with extremely high<br />

precision to be able to fully understand<br />

what’s happening when your system is<br />

misbehaving.”<br />

Beeks prides itself on being Capital<br />

Markets’ dedicated Infrastructure-asa-Service<br />

(IaaS) provider since 2011.<br />

Over the years they have honed the<br />

technology to support, monitor and<br />

protect trade executions and trading<br />

performance metrics in Capital<br />

Markets, Banks, and Financial Services<br />

companies.<br />

For this, the organisation provides the<br />

tools and services to ensure businesses<br />

have a high level of timely visibility<br />

of where in their trading network<br />

problems are occurring. They also<br />

have the expertise and knowledge<br />

to resolve performance issues in an<br />

agile manner, thus mitigating loss of<br />

profitability.<br />

“It’s not always easy to see what’s<br />

happening under the trading bonnet,<br />

and it’s dangerous to take a bargain<br />

basement approach to performance<br />

monitoring, especially during highprofile<br />

IPOs,” McArthur asserts. “A lot<br />

of businesses run the risk of being<br />

duped by their data. While things might<br />

look like they’re working properly,<br />

without the proper infrastructure it isn’t<br />

possible to see that things have broken<br />

until it’s far too late, and a lot of money<br />

has been lost.”<br />

A CAUTIONARY TALE<br />

To illustrate this, Beeks Analytics<br />

Chief Technology Officer (CTO), Steve<br />

Rodgers recalls a particular issue at<br />

a market participant as they tried to<br />

engage in the trading around Alibaba’s<br />

debut IPO back in 2014. He says: “The<br />

institution lost a significant amount<br />

Gordon McArthur<br />

of money during the Alibaba IPO<br />

and couldn’t work out how. With no<br />

58 JANUARY <strong>2024</strong> e-FOREX


EXPERT OPINION<br />

real-time monitoring and a reliance on<br />

reactive replays from their application<br />

logs, they had no visibility of what had<br />

actually gone wrong. They couldn’t<br />

see any faults, the market data ticker<br />

plant reported processing 100% of<br />

the data with no loss downstream to<br />

trading applications. Yet they still made<br />

a significant loss during trading.”<br />

Outlining how Beeks got involved,<br />

Rodgers says: “At the time the<br />

institution was aware of Beeks as a<br />

vendor for their performance lab and<br />

so they invited us to troubleshoot. We<br />

found that their incumbent hardwarebased<br />

market data ticker plant was to<br />

blame.The Alibaba IPO was causing<br />

microbursts the ticker plant could<br />

not keep up with when operating in<br />

low latency mode. Live market data<br />

feeds were overwhelming the system<br />

and causing delays. All the data was<br />

eventually delivered, but delayed<br />

just enough to give the bank a false<br />

position of what was happening<br />

at those extremely busy periods of<br />

market activity.”<br />

Beeks identified that the initial attempts<br />

to reproduce the problem from feed<br />

handler logs were unsuccessful because<br />

the microbursts were not captured<br />

correctly at the time and ended up<br />

being flattened out when replayed. It<br />

took a high-fidelity historical capture of<br />

the original trading day, replayed with<br />

nanosecond precision to reproduce the<br />

fault reliably.<br />

THE BIRTH OF THE MDPLAY<br />

In low-latency environments,<br />

performance analysis and network<br />

monitoring solutions are vital<br />

components. High-fidelity packet<br />

capture and precision replay<br />

capabilities give firms greater scope<br />

for more targeted drilling down and<br />

quicker resolution when issues arise.<br />

“In 2014 we used mdPlay to<br />

demonstrate the original fault to<br />

Steve Rodgers<br />

their ticker plant vendor who were<br />

eventually able to understand and<br />

resolve the problem,” says Rodgers.<br />

“This experience effectively gave rise<br />

to our unique mdPlay managed service<br />

offering. At the time mdPlay represented<br />

an all-in-one system to carry out all<br />

its own capture, replay and scenario<br />

management delivered as a turnkey<br />

managed service,” he says. “In the<br />

intervening decade, mdPlay has been<br />

automated, giving end-users instant<br />

visibility of scenarios on-demand and the<br />

ability to manage the tool themselves.”<br />

MDPLAY CAPABILITIES VS<br />

COMPETITORS<br />

Traditional solutions would read the<br />

recorded market data directly from<br />

storage and in doing so introduce<br />

latency and jitter which was not present<br />

in the original. These solutions also<br />

smooth out peaks in market data which<br />

would have potentially been the cause<br />

of application issues.<br />

mdPlay takes a different approach. It<br />

spools up the replay and pre-caches<br />

everything, resulting in maximum<br />

fidelity and accuracy in reproduction.<br />

The replayed scenarios are published<br />

to the network exactly as they were<br />

originally transmitted during live<br />

trading: a true like-for-like reproduction.<br />

mdPlay also replays data through the<br />

same infrastructure and code as the<br />

production path, which helps rule out<br />

or identify infrastructure causes.<br />

mdPlay also allows a library of<br />

scenarios to be built up to automate<br />

testing of system behaviour against<br />

known problematic market conditions<br />

- essential for QA and backtesting<br />

of algorithmic trading systems. In<br />

addition, mdPlay can alter the replay<br />

speed with precision - answering<br />

“what if?” questions such as ‘what<br />

if the markets were twice as fast’,<br />

or ‘what if we move from 10Gbit to<br />

40Gbit networks?’<br />

SUMMARY<br />

“As with all trade executions, Capital<br />

Markets businesses need a robust<br />

strategy, plan and infrastructure<br />

capability to take advantage of<br />

the best prices, whether public<br />

launch events or daily tick to trade,”<br />

comments CEO McArthur. “It’s a<br />

delicate and ongoing balance between<br />

timely trade and vigilant monitoring.<br />

mdPlay forms part of our suite of<br />

Analytics tools that enable exactly<br />

that.” In conclusion, McArthur says:<br />

“Essentially our competitors can point<br />

out problems. With mdPlay, you can<br />

anticipate and prevent them.”<br />

JANUARY <strong>2024</strong> e-FOREX 59


DATA MANAGEMENT<br />

Image by Shutterstock<br />

Vivek Shankar<br />

60 JANUARY <strong>2024</strong> e-FOREX


DATA MANAGEMENT<br />

Putting data at the heart<br />

of FICC business strategy<br />

By Vivek Shankar<br />

Fragmentation. Regulatory changes.<br />

Volatility. It’s safe to say the FX markets<br />

have posed significant challenges to<br />

market participants. Firms have long<br />

believed in the power of harnessing<br />

data to help them achieve higher levels<br />

of efficiency but have experienced a<br />

few hurdles.<br />

“Building and running a data pipeline<br />

is complex and expensive, especially<br />

at scale and with the performance<br />

levels that a trading firm needs,”<br />

says Stephen Totten, Director of<br />

Quantitative Analysis at oneZero.<br />

“Firms may have systems in place to<br />

capture data, but to use that data in<br />

a consistent and repetitive process<br />

means that they must be able to<br />

deal with outages, backfill missing or<br />

erroneous data, normalise data from<br />

multiple sources, and flag and clean<br />

any outliers.”<br />

Matthew Hodgson, Founder and<br />

CEO of Mosaic Smart Data, points<br />

to another issue. “Firms also need<br />

to extract insights from a growing<br />

number of unstructured data sources<br />

in addition to their internal client data,<br />

including newsfeeds and other macro<br />

sources.”<br />

DATA IMPLEMENTATION<br />

CHALLENGES AND TIMELINES<br />

Institutions draw data from several<br />

sources, and poor data organisation is<br />

creating silos that complicate analysis.<br />

“Firms trade with counterparties<br />

on multiple different channels-<br />

Single bank platforms, APIs, multidealer<br />

venues, and ECNs,” says<br />

Tim Cartledge, Chief Data Officer<br />

at Tradefeedr. “The result is that<br />

trading data is fragmented and overly<br />

complex. An independent trading data<br />

network provides a single, consistent<br />

view of trading data for all parties-<br />

Liquidity Providers, the buy-side, and<br />

trading platforms.”<br />

This network offers several benefits<br />

for all stakeholders, he explains. “LPs<br />

can demonstrate the quality of client<br />

pricing at review meetings and use<br />

analytics to optimise pricing engines<br />

and trading algos.”<br />

“Buy-side traders can make datadriven<br />

trading decisions that cut costs<br />

and maximise opportunities, while also<br />

proving best execution.” Cartledge<br />

points to Tradefeedr’s Algo Forecasting<br />

Model as an example of data driving<br />

productivity.<br />

“Against this backdrop, many FX<br />

trading firms struggle to unlock the<br />

value in their data and transform it<br />

into actionable insights.” Is the data<br />

challenge a step too far for FX market<br />

participants? Well, not quite. While<br />

challenges exist, technology is evolving<br />

to offer novel solutions.<br />

Buy-side traders leverage analytics to<br />

choose the most appropriate algo for<br />

a trade, and LPs can refine algos by<br />

analysing their performance.<br />

Totten also points to data’s benefits<br />

when monitoring client behaviour and<br />

using analysis conclusions to increase<br />

JANUARY <strong>2024</strong> e-FOREX 61


Putting data at the heart of FICC business strategy<br />

DATA MANAGEMENT<br />

“Building and running a data pipeline is complex and<br />

expensive, especially at scale and with the performance levels<br />

that a trading firm needs,”<br />

Stephen Totten<br />

market share. “If a client is increasing<br />

activity in a currency, or changing<br />

their hedging policy,” he explains,<br />

“sales can engage with the customer<br />

to understand what’s changed and<br />

recommend a better solution.”<br />

“Secondly, sales can feed that<br />

information to trading desks,<br />

helping them adapt pricing and<br />

risk management to service the<br />

new behaviour optimally. oneZero’s<br />

classification model for client flow<br />

management, for example, continuously<br />

monitors client trades and flags changes<br />

in trading profiles, helping firms<br />

proactively engage with their customers<br />

and rapidly react to changes.”<br />

Hodgson says a laser-like focus<br />

on productivity has been the key<br />

for firms that have navigated<br />

challenging market conditions this<br />

year. “Extracting insight from data is<br />

a critical step in enabling banks to do<br />

more with less,” he says.<br />

“To put this into context, following<br />

a recent pilot with Mosaic, a tier 1<br />

FX bank reported a 20% increase in<br />

call volumes, 22% increase in call<br />

duration, 18% increase in enquiries –<br />

and 100% of its users wanted to move<br />

to production immediately because of<br />

the extent to which they were able to<br />

enhance their productivity.”<br />

He’s quick to point out that such<br />

results need some foundational work.<br />

“It’s not quite as simple as flicking<br />

a switch and suddenly extracting<br />

actionable insight from your data.”<br />

“Firms need to start with a solid<br />

foundation of properly aggregated,<br />

normalised, and enriched transaction<br />

and market data. From this solid<br />

foundation, advanced analytics and<br />

AI tools can then begin to deliver<br />

value, providing insights across the<br />

organisation.”<br />

Cartledge explains that data<br />

normalisation used to be expensive,<br />

but data solutions providers now offer<br />

this as standard. “Also, there has been<br />

a view that firms need to hire their<br />

own data analysts to get value from<br />

the data,” he continues.<br />

“Again, this is not the case, some of<br />

our larger clients build their analytics<br />

using our data API, but many more<br />

use our pre-built reports to quickly get<br />

value from the data, like TCA reports.”<br />

Totten points out that conducting a<br />

normalisation exercise might cause<br />

trading firms more problems than it<br />

solves. “The FX markets have a wide<br />

range of trading venues and there can<br />

be considerable variation in protocols,<br />

as well as volume, depth, and quality<br />

of data, between different liquidity<br />

providers,” he says.<br />

“There is also a risk that in normalising<br />

the data the firm loses some key<br />

information from feeds, so a deep<br />

understanding of different venues and<br />

their protocols is very important.” He<br />

recommends working with a marketneutral<br />

technology vendor with prior<br />

expertise.<br />

Hodgson notes that data normalisation<br />

exercises tend to spiral out of control<br />

due to errors in the decision-making<br />

process. In turn, these errors increase<br />

costs and stretch implementation<br />

timelines unreasonably.<br />

Banks are looking to unleash AI and machine learning to take their data analytics to the next level<br />

“Surprisingly, many of these decisions<br />

have historically been based on<br />

emotion,” he says. “Decision-makers<br />

62 JANUARY <strong>2024</strong> e-FOREX


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JANUARY <strong>2024</strong> e-FOREX 63


DATA MANAGEMENT<br />

Putting data at the heart of FICC business strategy<br />

“Extracting insight from data is a critical step in enabling<br />

banks to do more with less,”<br />

Matthew Hodgson<br />

choose what ‘feels right,’ or rely<br />

on past experiences working with<br />

unrelated vendors on a different<br />

requirement. Ideally, decisions would<br />

be based on the key criteria of cost,<br />

efficiency, productivity, and speed to<br />

market, delivered through the lens of<br />

specialised capital markets expertise.”<br />

Totten and Cartledge agree with<br />

Hodgson that implementing a data<br />

solution in-house might lead to<br />

unreasonable timelines and costs. “As<br />

such it’s very important for firms to<br />

think carefully about what they want<br />

to build in-house,” Totten says. “Where<br />

they may have significant IP and what<br />

they want to buy to speed up that<br />

time of getting to market.”<br />

SIFTING THROUGH SERVICE<br />

PROVIDERS<br />

PARTNERING WITH THE RIGHT<br />

SERVICE PROVIDER IS CRITICAL<br />

So what can trading firms and banks<br />

expect from the latest generation of<br />

data solutions providers? Hodgson lists<br />

a few benefits. “A bank can achieve a<br />

single, holistic view of FX transaction<br />

data across all its global locations,<br />

across all trading channels, and all<br />

asset classes, combined with the<br />

relevant market data,” he says.<br />

This will help them unleash AI and<br />

machine learning to take their<br />

analytics to the next level, he adds.<br />

“Banks are now beginning to use AI<br />

to look at each client as their own<br />

segment, and hyper-personalise the<br />

insights and service they provide<br />

them,” Hodgson says.<br />

“This is optimised with natural<br />

language generation technology,<br />

which delivers reports such as multiasset<br />

morning briefings in a human<br />

tone of voice with easy-to-interpret<br />

analytics. The result for the bank is<br />

increased loyalty and a greater share<br />

of mind amongst clients.”<br />

Cartledge says Tradefeedr customised<br />

its offering based on client needs.<br />

“Many new clients start with standard<br />

analytical reports which auto-populate,<br />

then progress to a slightly more<br />

advanced and bespoke toolkit where<br />

users can select different tools or<br />

widgets to build their specific reports,”<br />

he says. “Our service is also available<br />

as an API feed for clients to capture<br />

our data directly into their systems to<br />

analyse the data themselves.”<br />

“oneZero has been working intensively<br />

in the data space for many years,”<br />

Totten says, “and we are now on<br />

our 4th-generation platform. Every<br />

iteration is improving on the last, and<br />

building extensive feedback into the<br />

next.”<br />

“Technology solution partners also<br />

need to be able to capture ever more<br />

data and devote more and more<br />

computing power to its analysis,” he<br />

adds, “which in practice now means<br />

access to significant cloud-based<br />

functionality.”<br />

“oneZero’s Data Source is a nextgeneration<br />

cloud-based intelligence<br />

toolkit that does just that, by<br />

capturing and modelling quote and<br />

trade data for our clients - their Data<br />

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JANUARY <strong>2024</strong> e-FOREX 65


Putting data at the heart of FICC business strategy<br />

“Another key point is that when you are using data analytics<br />

to prove Best Execution, independence matters.”<br />

everyone outside the very largest<br />

institutions could struggle.”<br />

Hodgson says the markets will soon<br />

DATA MANAGEMENT<br />

Tim Cartledge<br />

Source DNA as we call it.”<br />

All three point to experience as a<br />

critical factor when choosing a service<br />

provider to work with. “We partnered<br />

with the European Space Agency back<br />

in 2018 to explore how AI algorithms<br />

developed for use in space could<br />

be adapted and deployed in capital<br />

markets,” Hodgson says.<br />

“Fast forward to today, and this<br />

technology is in real-world deployment<br />

in live capital markets by a number<br />

of our customers who were able to<br />

benefit instantly from this cuttingedge<br />

technology that originated in a<br />

completely different field.”<br />

Totten stresses oneZero’s vast expertise<br />

too. “Deep industry knowledge<br />

combined with our expert technology<br />

and operations teams means that<br />

we are delivering solutions that add<br />

significant value for our clients,” he<br />

says. “We have a growing proportion<br />

of team members out of our total of<br />

over 170 staff who have wide-ranging<br />

experience from brokerages, banks,<br />

exchanges, and prime brokerages.”<br />

Cartledge says working with<br />

experienced service providers helps<br />

firms squeeze more out of their<br />

data and cites an example.”We<br />

would not have been able to launch<br />

algo forecasting without detailed<br />

knowledge of the FX market and<br />

specifically FX execution algos,”<br />

he says. “Another key point is that<br />

when you are using data analytics to<br />

prove Best Execution, independence<br />

matters.”<br />

WHERE ARE DATA SERVICES<br />

HEADED NEXT?<br />

AI and ML have hogged headlines<br />

this year, and Totten, Cartledge,<br />

and Hodgson are excited about its<br />

potential. When asked about future<br />

developments all three identify<br />

unleashing more AI use cases as the<br />

next frontier.<br />

“We are already using ML in our<br />

algo forecasting model and its use<br />

will continue to grow,” Cartledge<br />

says. Totten concurs and says<br />

that as AI models become more<br />

sophisticated, trading firms can<br />

expect huge results.<br />

“One of our models analyses client<br />

flows and markouts, for example,<br />

across millions of trades a day,”<br />

Totten says. “This analysis enables<br />

a more scalable and efficient<br />

understanding of trading styles<br />

and preferences, with the ability<br />

to segment information to ensure<br />

that FX flows are priced and risk<br />

managed optimally.”<br />

But he’s quick to caution that greater<br />

AI sophistication brings firms back<br />

to a central issue - Data volumes and<br />

management.<br />

“The more sophisticated the model,<br />

the more data is needed to train<br />

these to fully capture all of the<br />

market dynamics,” Totten continues,<br />

“and this is a key area where almost<br />

reach a stage where AI and ML-driven<br />

analytics will become table stakes.<br />

“Forward-thinking tech players<br />

continue to build on this innovation<br />

and shape the future of the industry<br />

for the years ahead,” he says.<br />

“There is never a good or bad time<br />

to be innovative, but in the current<br />

environment, all innovation should<br />

be laser-focused on helping achieve<br />

the business’s KPIs,” he adds.<br />

“Technology platforms will be judged<br />

by their ability to impact a bank’s<br />

bottom line without breaking the<br />

bank to deploy in the first place,<br />

and their strength when it comes to<br />

supporting change management.”<br />

Cartledge looks beyond AI and<br />

identifies another critical area service<br />

providers must develop. “Perhaps as<br />

important is data analytics services<br />

supporting cross-asset trading,” he<br />

says. “With this in mind, we are<br />

currently adding Futures and Equities<br />

to the Tradefeedr platform.”<br />

“It sounds obvious, but the value<br />

of FX data analytics comes from a<br />

combination of how much of the<br />

market is captured,” he continues,<br />

“the quality of the data, and the<br />

tools provided. The technology and<br />

tools are important, but equally so is<br />

the network.”<br />

While adopting data pipelines to<br />

boost trade efficiency is always<br />

challenging, firms have no choice but<br />

to tackle this complexity. Partnering<br />

with the right service provider is<br />

critical, of course.<br />

However, committing to build<br />

processes that extract the most from<br />

data is perhaps the most critical<br />

element in this picture.<br />

66 JANUARY <strong>2024</strong> e-FOREX


JANUARY <strong>2024</strong> e-FOREX 67


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