The group believed that the recommendations it made would be implemented by the market participants concerned and indeed, as I just said, they were supported by market participants at the time and endorsed by the FSB. There is a strong expectation they will be implemented. The recommendations are, however, not explicitly embodied in regulation.
Nevertheless, the group stated that if these recommendations were not acted on, authorities could conclude that a regulatory response was necessary to generate the desired improvement in market structure and conduct. Moreover, as a result of the investigations into the alleged misconduct, a regulatory response may be required and indeed, in the UK, FX benchmarks are now a regulated activity.