The FCA has stated that all FX derivative transactions and those FX spot transactions that are ancillary to transactions in MiFID financial instruments were within the scope of the best execution requirements set out in MiFID. Further, best execution would still apply when the firm was dealing as principal, including where dealing with a professional counterparty, where the counterparty was placing legitimate reliance on the firm. As regards other FX spot transactions, the FCA considered that the obligations arising would vary according to the nature of the relationship between market participants i.e. whether acting as agent, as principal or as principal with some discretion.