The market had to move toward a better place and allow market participants, and the public, to have much greater confidence that the FX market is functioning appropriately. It is also important to remember what the alternative was in the aftermath of the scandals.
There was a decent chance that authorities could conclude that a regulatory response was necessary to generate the desired improvement in market structure and conduct. But the Code provided the opportunity for a joint public/private sector approach to address the lack of trust and market dysfunction. The Code is not regulation.