This should help to address the lack of trust as well as promote the effective functioning of the wholesale FX market. To that end, one of the guiding principles underpinning the work on the Code is that it should promote a robust, fair, liquid, open, and transparent market.
From an EMDE perspective, the cross-border reporting and access to TR data has come out as a major issue which, as recommended, needs to be addressed legally. While the imperatives behind this are appreciated, their implementation would require navigating the existing privacy provisions nationally which may be challenging. As an alternative, to achieve early compliance, cooperative arrangements may also be considered pending legal frameworks.