The Global FX Code and what it says about last look
Posted: Wed Oct 28, 2026 6:26 am
After a series of scandals in the early 2010s, the foreign exchange industry developed the FX Global Code, a set of voluntary principles covering ethics, governance, execution, information sharing, risk management and confirmation. Central banks and many firms have signed statements of commitment.
One of the most discussed parts concerns last look, the practice of holding an order briefly before accepting it. The code doesn't ban it, but it requires transparency and sets expectations: last look should be used for validity and price checks, not to exploit information from the client's order, and firms should disclose how it's applied.
For retail traders, the code isn't directly enforceable. But the principles give a framework for questions to ask brokers and liquidity providers. Do they adhere to the code? Do they disclose last look practices? How do they treat client information?
Some brokers publish their statement of commitment. It's no guarantee of behaviour, but absence of any statement is worth noting.
Reading the code's summary takes half an hour and reveals what the industry itself considers good practice.
Practical takeaways drawn by many traders from that episode include simple rules: reduce size when a pair has had an extended one-way run and positioning looks stretched, avoid holding through scheduled Japanese policy events, and pay attention to funding currency behaviour in times of stress. Some also keep a list of past dislocations with the dates and the sequence of events.
A study of how spreads behaved in each such episode is also instructive. A scalper who logged spreads during that week would have seen figures several times the norm for hours, a striking reminder of how conditions can change.
Has a broker's code adherence or last look disclosure been checked before opening an account?
One of the most discussed parts concerns last look, the practice of holding an order briefly before accepting it. The code doesn't ban it, but it requires transparency and sets expectations: last look should be used for validity and price checks, not to exploit information from the client's order, and firms should disclose how it's applied.
For retail traders, the code isn't directly enforceable. But the principles give a framework for questions to ask brokers and liquidity providers. Do they adhere to the code? Do they disclose last look practices? How do they treat client information?
Some brokers publish their statement of commitment. It's no guarantee of behaviour, but absence of any statement is worth noting.
Reading the code's summary takes half an hour and reveals what the industry itself considers good practice.
Practical takeaways drawn by many traders from that episode include simple rules: reduce size when a pair has had an extended one-way run and positioning looks stretched, avoid holding through scheduled Japanese policy events, and pay attention to funding currency behaviour in times of stress. Some also keep a list of past dislocations with the dates and the sequence of events.
A study of how spreads behaved in each such episode is also instructive. A scalper who logged spreads during that week would have seen figures several times the norm for hours, a striking reminder of how conditions can change.
Has a broker's code adherence or last look disclosure been checked before opening an account?