The FCA has published a speech on conduct risk in the FX markets, which includes the following points of interest: (i) spot FX trading sits in an "interesting place" on the regulatory perimeter, because it is only within the perimeter in certain circumstances, for example where a spot trade is ancillary to a transaction in a regulated financial instrument. Most other spot trading is outside the perimeter with the result that there is not such a well elaborated body of regulations and rules; (ii) the FX market is a test case of whether, without extensive rule books, the market will or will not be characterised by the high standards that are expected of it; (iii) the FCA considers that the FX global code, as developed by the Bank for International Settlements and due to be launched in May 2017, provides an opportunity to establish common standards of good practice; and (iv) there is a link between the FX global code and the senior managers and certification regime (SM&CR), which is to be extended to authorised investment firms in 2018. In particular, the SM&CR has conduct rules that require individuals to "observe proper standards of market conduct". When the FX global code is completed, market participants can reasonably expect it to be a key component of these standards.