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transforming global foreign exchange markets

e-FOREX

e-forex.net MARCH 2025

CELEBRATING 25 YEARS OF PUBLICATION

DATA-DRIVEN

DECISION MAKING

Shaping the future of

FX trading

FX LIQUIDITY

MANAGEMENT

What’s driving the need

for more innovation?

FX GLOBAL

CODE UPDATE

Assessing the industry feedback

ARTIFICIAL

INTELLIGENCE IN FX

A game changer for all

market participants

HYBRID FX

Leveraging the strengths of

OTC and listed markets

COVER INTERVIEW

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DIRECTOR e-FX SALES AT SAXO

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2 MARCH 2025 e-FOREX


Welcome to

e-FOREX

transforming global foreign exchange markets

March 2025

An important focus for us in this edition is exploring how

data driven decision making is going to shape the future

of FX trading. Many commentators now agree that data is

emerging as both a catalyst and cornerstone of the digital

transformation that our industry is currently undergoing.

Increased electronification generates more data, which in turn

facilitates further automation and market sophistication. Data

is revolutionising electronic FX trading by boosting speed,

efficiency and decision-making. Firms who are adopting datacentric

operational models gain advantages across the entire

trading lifecycle, creating sustainable competitive edges in an

increasingly automated marketplace. However, the evolution

toward data-driven FX operations faces several significant

hurdles that firms must overcome to fully realise the benefits.

The issue of data availability varies significantly across FX

market segments and as data volumes expand, firms face

mounting challenges in storage, transport, and processing.

These technical considerations have significant implications for

operational efficiency and cost management. As our Special

Report this month points out the journey toward becoming

a data-centric institution involves more than just technology

upgrades. It requires fundamental shifts in organisational

culture, processes, and skills. As FX market participants

navigate this transformation, they must balance strategic vision

with practical implementation steps to maximise the value of

their data assets. At the same time the evolution of FX data

management platforms has profoundly transformed how

market participants interact with and extract value from their

data.

While data management capabilities continue to evolve in

the FX market, artificial intelligence and machine learning

are reshaping how firms extract value from their information

assets.The dramatic and sweeping changes that are being

brought forward by AI and ML will be most richly reaped by

firms that have the best understanding of their own data.

In order to quantify the value that AI-driven data analytics

can offer FX trading firms, Mosaic Smart Data conducted a

survey among its global user base. The results, which Matthew

Hodgson tells us about in his Expert Opinion feature in this

edition tell a powerful story about how AI is delivering tangible

and measurable value to his firms FX clients, transforming the

way they operate and perform. We agree with his assessment

that AI isn’t just another tool, it’s a game-changer for any FX

business looking to outperform and over-deliver.

Susan Rennie

Susan.rennie@sjbmedia.net

Managing Editor

Charles Jago

charles.jago@e-forex.net

Editor (FX & Derivatives)

Charles Harris

Charles.harris@sjbmedia.net

Advertising Manager

Ben Ezra

Ben.ezra@sjbmedia.net

Retail FX Consultant

Michael Best

Michael.best@sjbmedia.net

Subscriptions Manager

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Digital Events

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mail@ingridweel.com

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Tel: +44 (0) 1736 74 01 30 (Switchboard)

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Design and Origination:

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Printed by Headland Printers

e-Forex (ISSN 1472-3875) is published bi-monthly

www.e-forex.net

Membership enquiries

Access to the e-Forex website is free to all registered

members. More information about how to register

can be found at www.e-forex.net

To order hard copies of the publication

or for more information about membership

please call our subscription department.

Members hotline: +44 (0)1736 74 01 30

Although every effort has been made to ensure the accuracy of the information

contained in this publication the publishers can accept no liabilities for

inaccuracies that may appear. The views expressed in this publication are not

necessarily those of the publisher.

Please note, the publishers do not endorse or recommend any specific website

featured in this magazine. Readers are advised to check carefully that any

website offering a specific FX trading product and service complies with all

required regulatory conditions and obligations.

The entire contents of e-Forex are protected by copyright and all rights are

reserved.

As usual I hope you enjoy reading this edition of the magazine.

Charles Jago

Editor

MARCH 2025 e-FOREX 3


March 2025

CONTENTS

REGULATORY

ISSUES & CONDUCT

12. FX algo execution and the

updated FX Global Code

Stéphane Malrait ACI Financial

Markets Association (ACI FMA)

Chairman, shares his thoughts

on some of the aspects of the

recently updated FX Global Code.

PRODUCT

SPOTLIGHT

15. NCFX Options Cut:

Automating the FX market one

step at a time

Arun Sundaram tells us about

how traders are leveraging

LMAX data to optimise their FX

trading operations and execution

strategies.

PROVIDER

VIEWPOINT

48. The FX Swaps market in 2025

– All change

Stephan von Massenbach talks

to e-Forex about how DIGITEC

continues to innovate to stay

at the forefront of FX Swaps

technology.

CONTENTS

Stéphane Malrait

FX Global Code

Vivek Shankar

FX data

Stephan von Massenbach

FX Swaps

Nicholas Pratt

Liquidity Management

James Dewdney-Herbert

e-Forex Interview

KC Lam

Hybrid FX

LIQUIDITY

MANAGEMENT

16. What’s driving the need for

more innovation in FX liquidity

management?

As regulatory and competitive

pressures continue to influence

liquidity management demands,

Nicholas Pratt asks where the next

wave of innovation is coming from.

MARKET INSIGHTS

30. Paul Lambert discusses

unlocking the power of granular

data to transform the Forward

FX market

SPECIAL REPORT

32. Why data-driven decision making

will shape the future of FX trading

Vivek Shankar explores the benefits

of data-driven decision-making in FX

and how firms can overcome some

of the common hurdles involved.

PRODUCT

PERSPECTIVE

46. Exploiting the raw power of

FX data: A product perspective

from LMAX Exchange

E-FOREX INTERVIEW

50. Saxo Bank: From online

broker to global banking group

With James Dewdney-Herbert,

Director of e-FX sales at the firm.

EXPERT OPINION

58. AI in FX: Hype or highperformance?

Matthew Hodgson describes

how the results of his company’s

recent survey tell a powerful

story about how AI is delivering

tangible and measurable value to

its clients.

ASK A PROVIDER

69. Hybrid FX: leveraging the

strengths of both OTC and listed

markets

KC Lam talks about some of the

benefits of combining OTC and

listed markets.

RECENT EVENT

62. 5 key takeaways from

TradeTech FX USA 2025

The 360T team provide a roundup

of their key takeaways from this

recent event.

COMPANIES IN THIS ISSUE

A

Alp Financial

B

Beeks

Bloomberg

C

Centroid Solutions

Citi

p19

p8

p4

p65

IFC

D

26 Degrees Global Markets p37

Definity Markets

p8

Devexperts

p10

Devexa

DIGITEC

DTCC

F

FastFin Labs

Finalto

FXSpotStream

G

GlobalLink

I

IPC

p4

p48

p4

p8

p27

IBC

p41

OBC

K

Krajen

L

LMAX Group

LSEG

M

Mosaic Smart Data

N

New Change FX

O

oneZero

p8

p39

p25

p43

p15

p35

P

PLUGIT

S

Saxo

SGX FX

smartTrade Technologies

StoneX

Swissquote Bank

T

360T

T.Rowe Price

p9

p5

p21

p23

p13

p7

p62

p31

4 MARCH 2025 e-FOREX


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Read Saxo’s full disclaimer at www.home.saxo/legal/disclaimer/saxo-disclaimer.

MARCH 2025 e-FOREX 5


DTCC’s GTR to add MiFID/R reporting capabilities

The Depository Trust & Clearing

Corporation (DTCC) has announced

its plans to add a Markets in Financial

Instruments Directive/Regulation

(MiFID/R) ARM service to its Global

Trade Repository (GTR) service in

support of evolving transaction and

trade reporting requirements. Subject

to regulatory approval, the service is

targeted to be launched in the UK by

Q1 2026 and in the EU in line with

the upcoming regulatory changes.

Once launched, GTR’s MiFID/R

capabilities will enable firms to fulfil

their transaction reporting obligations

under the regulation. Firms will also

Michele Hillery

benefit from ancillary services such as

data quality analytics as well as smart

tooling to assist with monitoring,

controls and exception management.

“In support of the industry’s evolving

trade and transaction reporting

needs, we look forward to working

closely with key stakeholders

to launch the new GTR MiFID/R

capabilities in early 2026 following

regulatory approvals,” said Michele

Hillery, DTCC Managing Director and

Head of Repository and Derivatives

Services.

NEWS

FX market in Sri Lanka chooses Bloomberg’s BMatch solution

The FX market in Sri Lanka has chosen

Bloomberg’s BMatch solution for

interbank trading in the local spot

foreign exchange market. FXGO’s

BMatch solution offers matching

functionality to the local interbank

community for spot US Dollar against

the Sri Lankan Rupee (LKR). BMatch

allows anonymous orders to be placed

into a central limit order book, which

are displayed and then matched with

counterparty orders based on mutual

trading limits and other parameters

configured by each bank. “Robust

and efficient financial markets will

Rajiv Mirwani

play a key role in the future growth

of Sri Lanka’s economy. Bloomberg

is well-placed to provide technical

infrastructure solutions for FX markets

and can easily adapt these to the

specific needs of any market around

the world. We are delighted to support

the FX Market in Sri Lanka with our

BMatch solution, which will help

boost liquidity in the local FX market

while making it more transparent and

efficient.” said Rajiv Mirwani, head of

Bloomberg, South Asia.

Devexa launches new community feature

Devexa, the AI-powered

trading assistant and trader

engagement bot from global

software developers for the

capital markets, Devexperts,

has launched a new community

feature, enabling brokers to host

a secure environment in which

traders can engage with each

other, all within the broker’s own

ecosystem. The new feature will

allow traders to exchange ideas on

market movements and investment

strategies without having to leave

the platform where they trade.

Commenting on the launch, Jon

Light, Head of OTC Platform at

Jon Light

Devexperts says, “Devexa’s new

community feature will enable

brokers to provide traders with the

opportunity for interaction and

community-building they seek, with

a number of key advantages. The

safety of interactions is amplified for

those using the Devexa community

feature, compared to other popular

communication platforms, whilst

the ability to use the community

feature within their trading platform

improves traders’ overall experience,

offering seamlessness and

convenience.”

6 MARCH 2025 e-FOREX


LIQUIDITY

SOLUTIONS

THAT OPEN

NEW

HORIZONS

swissquote.com/institutional

MARCH 2025 e-FOREX 7


FastFin Labs creates FXswapX platform

FastFin Labs has built FXswapX, an FX

swaps matching platform designed

specifically for banks to exchange risk

with each other, with minimal market

impact or information leakage. As a

leading creator of trading applications

and workflow automation solutions for

banks, vendors, venues, and buy-side

firms, FastFin Labs does not normally

own and operate its own creations.

Therefore, it expects to partner with a

new or existing industry consortium

to bring FXswapX to market quickly

and globally, with the full regulatory

and operational support of the

partner. Richard Leader who leads the

firm said: “FXswapX was built using

FastFin’s proven Innovation Kickstarter

methodology for rapidly prototyping and

productionizing fully-functional trading

applications – the very same process

that we use for our capital markets

clients and previous incubations such

as FX HedgePool. We will continue to

refine the solution based on participant

feedback, but we are ready to

demonstrate the product today and are

on target for a full launch later this year.”

Richard Leader

DeFinity Markets partners with Utila

NEWS

DeFinity Markets and Utila have

announced a strategic partnership

to provide institutional clients with

enhanced access to digital asset

markets, featuring secure fiat on/

off ramping and FX solutions. This

collaboration builds upon DeFinity’s

commitment to providing a full-stack

institutional digital asset platform.

The partnership combines DeFinity’s

advanced order matching and

settlement capabilities across FX

and digital assets with Utila’s secure,

non-custodial, and chain-agnostic

wallet infrastructure. This powerful

combination will enable institutional

clients to seamlessly and securely

manage their digital asset operations,

Manu Choudhary

from fiat on/off ramping to trading

and settlement, all within a unified

and compliant framework.

“We are thrilled to partner with

Utila to further enhance our offering

for institutional clients,” said Manu

Choudhary, CEO and founder of

DeFinity Markets. “Secure and efficient

fiat on/off ramping and FX solutions

are critical for institutions entering

the digital asset space. Utila’s robust

platform complements our existing

infrastructure and allows us to provide

a truly comprehensive solution.”

Kraken engages Beeks to launch a colocation service

Kraken has announced plans for its

new colocation service, aimed at

clients and partners seeking ultra-fast

execution. The service is designed to

further enhance trading performance

and scalability, while maintaining fair

and transparent access to Kraken’s

global crypto markets. Starting later

this year, Kraken clients will be able

to access ultra-low latency trading

from Kraken’s European data center

by renting cloud compute from Beeks,

a leading provider of low-latency

compute, connectivity and analytics

solutions. Eligible clients with specific

technical requirements will also have

the option to install physical hardware

at Kraken’s data center and access

colocation services directly.

“Kraken has spent over a decade

continuously enhancing our

infrastructure and technology, and this

is the next step in that evolution,” said

Shannon Kurtas, Head of Exchange at

Kraken. “By working with Beeks, we’re

facilitating even lower latency, more

efficient price discovery and deeper

liquidity for all of Kraken’s spot and

derivative markets.”

Shannon Kurtas

8 MARCH 2025 e-FOREX


MARCH 2025 e-FOREX 9


DXtrade Institutional:

The new custom-built trading

platform from Devexperts

Devexperts has over 20 years of experience in software development and consulting for the global

capital markets. The firm offers a proven track record in the delivery of institutional FX trading

solutions, with extensive expertise in institutional-grade trading infrastructure and API-driven

architectures. It recently launched a new single-dealer platform called DXtrade Institutional so we

asked Nick Mortimer, who heads up its institutional business development, to tell us more about

this initiative.

PRODUCT LAUNCH

Nick Mortimer

DXtrade Institutional is the first

DXtrade product that is not an

off-the-shelf solution. Why did

Devexperts decide to launch

this platform and who are you

specifically targeting with it?

The decision to launch DXtrade

Institutional has come in direct

response to demand we have

been seeing in the market. From

conversations we were having, we

could see that institutions are looking

for, and in many cases really need,

a GUI that matches not only theirs,

but also their customers’, often very

specific requirements. With over 20

years’ experience developing software

for the capital markets, customisation

has become one of our specialities,

and we are, as a result, very happy to

be bringing this deep expertise to the

institutional space, where we know it

will meet a real need. It is exciting to

add this aspect of what we do to the

DXtrade armoury.

DXtrade Institutional will be built

on a bespoke basis. What does that

mean and how do you make the

process of doing this from the clients

perspective as easy as possible?

From our experience as one of the

leading trading software developers,

we have designed a special framework

that has been built specifically for

this process. The composition of

this framework allows us to add

a customer’s unique features and

functionalities to the already included

‘standard’ functionalities. This gives

them the full customisation they

require, efficiently, thereby delivering a

cost- and time-effective solution.

Please tell us a little about some

of the key features and multi-asset

trading functionality that DXtrade

Institutional offers?

DXtrade Institutional is not an off-the-shelf product

DXtrade Institutional provides a

framework for delivery of customised

GUIs, and each end-product will

be different, with each completed

GUI reflecting the specific needs

of the institution they are built

for. Unlike others in the DXtrade

range, DXtrade Institutional is not

an off-the-shelf product, however,

in each case the aim will be to offer

10 MARCH 2025 e-FOREX


PRODUCT LAUNCH

With over 800 engineers operating worldwide, Devexperts is specialised in the customisation of front ends

the standard functionality that can

be found in most SDP GUIs, plus

customisation according to clients’

specific needs through our framework.

Customisations could include,

for example, multi-asset trading

functionality or any other unique

functionality the customer requests.

What range of instruments does

DXtrade Institutional support?

Initially, DXtrade Institutional will

support spot, forwards, swaps,

options, and NDFs. This said, as a

product developed directly in response

to customer demand, should we see

demand for other instruments, we will

adapt in line with this.

How customisable and adaptable is

the new platform?

Totally customisable. DXtrade

Institutional is by nature a 100%

customisable product. At Devexperts

we have 20+ years of creating

enterprise trading platforms so

customisation is something we are

very good at and that is why we are

coming to market with this particular

product because it allows us to use

our strengths, and, more importantly,

for institutions to access and use these

strengths! With this product, we take

specifications and build a platform

that institutions and their customers

require and we will do this in a costand

time-effective way.

Institutions have complex trading

requirements. In what ways have

you engineered the platform to try

and meet their unique operational

and deployment needs?

The complex trading requirements of

institutions is the reason why DXtrade

Institutional is so relevant. We know

that the complexity of institutions’

trading requirements is a hurdle

that prevents many from updating

their legacy interfaces. Harnessing

our experience, we have created this

framework that enables us to work

with customers to develop something

that meets their very specific needs,

and does so efficiently, from both a

cost and time-frame point of view.

One stand out aspect of DXtrade

Institutional is that it comes with a

dedicated team of trading software

development experts. In what ways

will this benefit your clients and help

you to build long term relationships?

Building customisable solutions for

our clients is our core business. It’s

been our business for a significant

period of time. With over 800

engineers operating worldwide, we

are specialised in the customisation

of front ends and will assign each

customer teams to both create the

customised GUI and maintain that GUI

in the future.

Software is ever evolving and the

long-term relationships we build

with our customers are borne out

of our commitment to ensuring our

products are maintained at optimum

efficiency far beyond the point of

sale. This includes the implementation

of updates from our side, but also

responsiveness to evolving customer

needs over time and the adaptation of

the product in accordance with these.

How can institutions get more

information about the platform?

DXtrade Institutional is available

globally. To learn more about DXtrade

Institutional or if you would like a

conversation to talk through how

we can help, you can contact us via

our website: https://devexperts.com/

contact-us/.

MARCH 2025 e-FOREX 11


FX algo execution and the

updated FX Global Code

By Nicola Tavendale

REGULATORY ISSUES & CONDUCT

As part of its most recent review of the FX Global Code, the Global Foreign Exchange Committee

(GFXC) conducted an extensive consultation process with the global FX committees in addition to a

formal request for feedback from market participants last October. Stéphane Malrait ACI Financial

Markets Association (ACI FMA) Chairman, shares his thoughts on how certain forms of outsourced

trading, such as FX algo execution, would possibly have been impacted by the initial proposals as

compared to the final wording of the Code.

Nicola Tavendale

ACI FMA, representing the interests

of the professional wholesale financial

markets community, responded to the

request for feedback with detailed

notes and suggestions, including

concerns about whether the proposed

changes to the wording of Principle

10 may “unintentionally bring other

order types into the scope of this

text, such as fixing orders, and orders

submitted for algorithmic execution”.

In the response, ACI FMA noted that

the proposed changes to Principle

10, which states that market

participants should handle orders

fairly, with transparency, and in a

manner consistent with the specific

considerations relevant to different

order types, should be clear that

this includes delegated or managed

execution. In the letter, Malrait,

along with Kim Winding Larsen, ACI

FMA President at that time, added

that delegated/managed execution

is a “sufficiently complex subject

that it warrants separate additional

guidance”.

Following the publication of the

December 2024 updated version of

FX Global Code, Malrait says that

these concerns were addressed to

some extent in the finalised version.

“The focus was modification of

some of the existing Principles and

clarifications around the existing

text,” he says. “One area that was

changed was the wording related

to outsourced execution. The goal

of this was mainly to highlight that

when you outsource execution, such

as by using a custodian, or those

type of activities where you are not

in control of the parameter to the

execution, that you have handed

the responsibility to somebody else

to do the execution for you. What

had been missing from the original

Code was documentation around

how the outsourcing of execution

works in practice and how providers

can offer you evidence of execution

performance through the use of TCA,

for example.”

NEED FOR ADDITIONAL

CLARITY

Malrait explains that with the

introduction of algo templates and

questionnaires following the previous

revision of the Code, those measures

had already been put in place. “When

a market participant uses an algo,

12 MARCH 2025 e-FOREX


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© 2024 StoneX Group Inc. all rights reserved. The StoneX Group of companies provides financial services worldwide, including physical commodities, securities, exchange-traded futures and options, OTC

instruments, risk management and advisory services, global payments and foreign exchange products. StoneX Financial Inc. (“SFI”) is a subsidiary of StoneX Group Inc., a member of FINRA/NFA/SIPC and

registered with the MSRB. SFI is registered with the U.S. Securities and Exchange Commission (“SEC”) as a Broker-Dealer and with the CFTC as a Futures Commission Merchant and Commodity Trading

Advisor. References to securities trading and prime services are made on behalf of the BD Division of SFI. References to exchange-traded futures and options are made on behalf of the FCM Division of SFI.

You can learn more about the background of StoneX Financial Inc. on BrokerCheck.

No part of this material may be copied, photocopied or duplicated in any form by any means or redistributed without our prior written consent. This document and the information herein are provided

confidentially for information purposes only to the recipient. The information herein is not advice nor a recommendation to trade nor an offer to buy or sell any financial product or service. It does not take into

account your particular investment objectives, financial situation or needs and does not create a binding obligation on any of the StoneX Group of companies to enter into any transaction with you. You should

perform an independent investigation of any transaction to determine whether it is suitable for you.

This information is provided on an ‘as-is’ basis and may contain statements and opinions of the StoneX Group as well as excerpts and/or information from public sources and third parties and no warranty,

whether express or implied, is given as to its completeness or accuracy.

MARCH 2025 e-FOREX 13


FX algo execution and the updated FX Global Code

Furthermore, a response from ANZ

to Principle 10 call for enhanced

also recommended that the GFXC

transparency obligations which will

undertake more consultation and

enable the client to have greater

review around the wording of its

visibility on order handling by the

proposed changes to Principle 10.

principal, transparency on fees/

“The proposed changes are open

costs, and enhance the ability to

to interpretation and requires more

conduct post-trade reviews to assess

clarity. In the current form it could

the quality of execution,” the final

be interpreted that this paragraph

wording reads.

will apply to all transactions that

are subject to a written agreement,

ACI FMA, in its feedback to the

including for example large

GFXC, also suggested a longer

REGULATORY ISSUES & CONDUCT

Stéphane Malrait

they are effectively outsourcing

their execution to that algo provider

– and the Code has already put

in place documentation to reflect

that,” he adds. “What is now being

recommended in the new version of

the Code is that market participants

look at the impact of the different

changes to the Principles of the Code

on their business. There is no black

and white answer as this depends on

what type of algo participants use

when outsourcing those executions.

Are they still in control of some of

the parameters? Do they receive a

TCA with their existing contract or

not? The best practice will be for

participants to review the changes

that have now been made to the

Code in relation to how it will impact

their business. For algo executions,

the changes should have minimal

impact.”

ACI FMA were not alone in

highlighting the need for additional

clarification around the proposed

changes to Principle 10. An additional

response, which requested that the

GFXC withhold its company name,

had also noted the scope of the

transactions is not clear, adding:

“We believe that general bank

transactions such as client orders

and algorithmic transactions are not

included. Please clarify that these

transactions are outside the scope.”

transactions,” ANZ said, adding: “The

proposed changes are moving away

from Principle based guidelines to

prescriptive requirements.”

In December, the GFXC published

the updated version of the Code

after having conducted “an extensive

process of review and public

consultation (Request for Feedback).”

The tri-annual review of the Code

FX Global Code started with the

GFXC survey for market participants

in 2023 to gauge its effectiveness,

followed by input in 2024 from the

Bank for International Settlements

(BIS) Markets Committee and local

FX committees (LFXCs) to finalise the

priorities for this Code Review.

LONGER TIMELINES AND

INCREASED ADOPTION

Among the targeted changes, the

GFXC says it had identified the

need to, “enhance transparency

obligations around certain types of

delegated execution activity”. The

amendments to Principle 10 aim

to outline the need for heightened

transparency around the execution

of FX transactions which have been

delegated to a service provider who,

the GFXC says “also acts as principal

to the trade from a counterparty

perspective”. Under this type of

execution, the GFXC says that the

principal initiates the trade on

behalf of the client as authorised

under a written agreement in

advance of trading. “The revisions

response period would allow market

participants more time to carry out

internal discussions and respond

to the survey. “For future surveys,

a longer response window would

be beneficial to the GFXC to obtain

feedback from a broader range of

market participants, enhancing the

quality and inclusiveness of the

feedback received,” ACI FMA said.

Following the publication of the

revised 2024 version of the Code,

an ongoing area of importance is

to increase buyside adoption of the

Code, Malrait adds, with a working

group focusing on how to further

increase outreach and awareness

among those who trade FX. “The

Code was originally created to benefit

buyside firms. Using the example

of algorithmic trading, buyside

participants will want to ensure that

best practice is applied and that they

have appropriate disclosure with the

counterparty they are dealing with for

their execution.

If they follow the algorithm template

and they have signed up to the

Code, this provides them with that

additional level of reassurance. Code

adoption is voluntary, but buyside

participants are increasingly aware of

the Code and understand the Code,

but many have still to sign up to the

Statement of Commitment. More

work is being done to encourage that

next step in the formal adoption of

the Code.”

14 MARCH 2025 e-FOREX


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processes like trade confirmations,

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The options expiry process fits

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TRANSPARENCY AND

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LIQUIDITY MANAGEMENT

Image by Shutterstock

16 MARCH 2025 e-FOREX


LIQUIDITY MANAGEMENT

What’s driving

the need for more

innovation in FX

liquidity management?

As regulatory and competitive pressures

continue to influence liquidity management

demands, Nicholas Pratt asks where the next

wave of innovation is coming from

Nicholas Pratt

MARCH 2025 e-FOREX 17


LIQUIDITY MANAGEMENT

What’s driving the need for more innovation in FX liquidity management?

“Instead of rigid liquidity solutions, firms are looking for

providers that can tailor pricing streams and execution models

to match their specific needs.”

Andrea Sanna

Technology and the move from voice

to electronic trading have left their

indelible marks on the FX market and

on liquidity management specifically.

Technology has undoubtedly made

the market more efficient and

transparent but it has also made

it more fragmented and more

complex. As a consequence, liquidity

management has become a much

more complicated process, requiring

much greater use of technology and

third-party services.

Participants are looking for more

diverse liquidity sources to ensure

they are both competitive and also

compliant with best execution

rules and the FX Global Code of

Conduct. This has led to the growth

of the liquidity management service

providers who have added advanced

analytics to their offerings to help

clients asses execution quality and

manage fragmented liquidity more

efficiently.

But what are the next steps in liquidity

management? Is there a role for AI

and other advanced technologies?

And what will greater use of these

tools do to the relationship between

liquidity takers and makers and the

various intermediaries that stand

between the two?

FRAGMENTED MARKET

Liquidity management is becoming

more and more complex due to a mix

of factors, says Andrea Sanna, head

of liquidity management at Londonbased

FX broker Alp Financial. “The

FX market is getting increasingly

fragmented, with liquidity spread

across multiple venues, making it

harder to aggregate efficiently. This

fragmentation leads to inefficiencies,

price discrepancies, and challenges

in ensuring the best execution,” says

Sanna.

“At the same time, regulatory

pressures are pushing firms to diversify

their liquidity sources to comply

with best execution rules and the FX

Global Code of Conduct. This adds

another layer of complexity, as firms

Liquidity management has become a much more complicated process

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What’s driving the need for more innovation in FX liquidity management?

LIQUIDITY MANAGEMENT

The industry is also seeing a push for more customised liquidity solutions

must navigate reporting requirements

and demonstrate that they are

sourcing liquidity in a competitive and

transparent way,” he says.

“On top of this, the growing reliance

on electronic trading and algorithmic

execution has increased technological

complexity. Firms are investing heavily

in advanced analytics to measure

execution quality and optimise liquidity

management strategies. Managing

fragmented liquidity effectively now

requires improved real-time data

processing, AI-powered decision-making,

and smart order routing systems, all of

which demand significant technological

investment,” says Sanna.

Liquidity providers are no longer just

market makers, they are evolving into

technology and data providers as well,

says Sanna. “The growing demand

for transparency means they need to

offer deeper insights into how liquidity

is sourced and priced. Clients expect

detailed reporting and execution

analytics to ensure they are receiving

fair and competitive pricing.There is

also increasing pressure to improve

execution quality. Firms on the buyside

are becoming more demanding,

and they ask for lower slippage and

reduced market impact. As a result,

liquidity providers are investing in

providing real-time analytics and

algorithmic execution tools to stay

competitive,” says Sanna.

“Additionally, as the market shifts

toward multi-asset trading, liquidity

providers are expanding beyond

FX to offer liquidity across multiple

asset classes. This requires them to

develop more flexible and adaptive

pricing models. The industry is also

seeing a push for more customised

liquidity solutions, which has led

liquidity providers to offer tailored

pricing streams and execution models

that align with individual trading

strategies,” says Sanna.

At the heart of this transformation

is technology, says Sanna. “Liquidity

providers that fail to embrace

automation, AI, and machine

learning risk losing relevance as their

competitors use these tools to refine

pricing, improve risk management,

and provide clients with better

execution outcomes. AI and machine

learning are revolutionising FX

liquidity management by making

execution more precise, automated,

and predictive. One of the biggest

impacts has been in market

forecasting. AI-driven models analyse

vast amounts of historical and

real-time data to anticipate liquidity

conditions and price movements. This

allows liquidity providers to adjust

pricing dynamically, ensuring better

execution,” says Sanna.

Smart order routing is another area

where AI is making a difference, says

Sanna. “With liquidity now highly

fragmented across multiple trading

venues, AI-powered algorithms help

route orders to the best available

liquidity pools, reducing costs and

improving fill ratios. Risk management

is also being enhanced by machine

learning. These models can

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LIQUIDITY MANAGEMENT

What’s driving the need for more innovation in FX liquidity management?

“Once upon a time it was enough to adjust pricing by client

tier, pair, tenor and size. Those days are long gone for the

market making clients looking to win new business.”

John Stead

continuously scan market conditions

and adjust risk exposure in real time,

helping liquidity providers react

quickly to market shifts and mitigate

potential disruptions.”

Additionally, automated marketmaking

strategies are becoming

more sophisticated, says Sanna. “AI is

being used to refine bid-ask spreads

dynamically based on order flow,

volatility, and liquidity conditions.

This results in more stable liquidity

provision and better pricing for clients.

As AI continues to advance, liquidity

management is becoming more

efficient, data-driven, and responsive,

enabling firms to navigate market

complexities with greater agility.”

The relationship between liquidity

providers and their clients is shifting

from a simple transactional model

to a more data-driven, collaborative

partnership. One of the key factors

driving this change is the increasing

demand for transparency. Clients

want more insight into execution

quality, pricing, and the true cost of

liquidity. As a result, liquidity providers

are now offering more detailed

execution analytics and post-trade

reporting to meet these expectations.

Another major change is the way

firms evaluate their liquidity providers.

Instead of simply looking at spread

costs, they are analysing execution

performance, market impact, and

the consistency of liquidity provision.

This has led to increased competition

among providers to deliver not just

liquidity, but also smarter, more

adaptive execution tools.

Multi-venue and multi-asset liquidity

are also playing a role. As firms look

to diversify their liquidity sources and

trade across different asset classes,

providers must adapt by offering

cross-asset and multi-market liquidity

solutions. This has led to a more

customised approach, with providers

tailoring their offerings to meet the

specific needs of different trading

strategies.

These shifts are creating a more

dynamic and competitive landscape,

where liquidity providers must

continuously innovate to stay relevant.

While size has historically been an

important factor in liquidity provision,

it is no longer the sole defining

characteristic of a top-tier provider,

says Sanna. Technology, execution

quality, and transparency are

becoming even more crucial.

“Firms are prioritising providers that

can deliver high-quality execution

with minimal slippage and market

impact. Clients want to understand

how pricing is determined and

whether spreads are fair. Providers

that can offer robust reporting and

post-trade analytics are gaining

an advantage. Customisation and

flexibility are also becoming essential.

Instead of rigid liquidity solutions,

firms are looking for providers

that can tailor pricing streams and

execution models to match their

specific needs. In this evolving

landscape, investing in emerging

markets and innovation, while keeping

the business costs lean, are proving

to be more valuable than sheer size

alone,” says Sanna.

The future of FX liquidity management

will be shaped by AI-driven execution,

real-time liquidity optimisation, and

seamless multi-venue integration.

Advanced execution algorithms and

predictive analytics will play a key role

in optimising liquidity sourcing and

reducing market impact, says Sanna.

“Machine learning will enhance risk

management by dynamically adjusting

liquidity provision based on realtime

market conditions. Firms will

also demand deeper data insights,

leading to greater use of analytics

dashboards that provide real-time

execution performance metrics. In

this next-generation environment,

liquidity providers will need to offer

a combination of cutting-edge

technology and customisation to stay

ahead in an increasingly complex

market.”

REGULATORY AND

COMPETITIVE PRESSURES

One complicating factor influencing

liquidity management is the potential

for pricing feeds to be contaminated

while passing from price maker to

price taker, says John Stead, Director

of Sales Enablement, Strategy, and

Marketing at smartTrade..

“For example if the feed passed

through a venue that charges the

maker then inevitably the maker will

have to make a call if they will forgo

some potential profit and leave pricing

unchanged; add some additional

markup to compensate; stop pricing

via that venue or take other non-

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What’s driving the need for more innovation in FX liquidity management?

LIQUIDITY MANAGEMENT

AI and machine learning are revolutionising FX liquidity management

price action such as reducing depth

or increasing sensitivity of last look

controls. Only a transit route such

as direct bank connectivity provided

by smartTrade or a venue like

FXSpotStream will give clean pricing

feed upon which one can build an

accurate book and the basis for best

execution,” says Stead.

A combination of regulatory and

competitive pricing pressures are

redefining participants’ roles in terms

of liquidity management, especially

well-known market makers that must

prove their pricing is legitimate and

auditable, says Stead. “A number

of years ago we added a significant

amount of granular control, logic and

audit logs to our last look controls

to ensure that if banks chose to

apply such checks on flow that it was

done in a manner entirely consistent

with their FX Global Code of

Conduct obligations and any service

declarations made to clients. We saw

that clients needed to extract more

and more data via APIs to record how

client pricing streams had been build

and orders filled both to allow them

to improve the service they offered

but also to enable them to prove

best execution and best pricing was

followed at all times,” says Stead.

On the competitive pricing side,

smartTrade’s market-making clients are

looking in ever more granular detail to

differentiate their pricing, says Stead.

“Once upon a time it was enough to

adjust pricing by client tier, pair, tenor

and size. Those days are long gone for

the market making clients looking to

win new business.”

Now, says Stead, the demand is for

more tailored liquidity and pricing.

“The competition might result in

tighter spreads but that is a welltrodden

path. Other aspects of

pricing that can be adjusted to give

extra value include our maker bank

clients offering pricing with longer

hold times for selected end clients

where due to some underlying

business reason they need a fixed

price to check the economics of

a deal, of course makers offering

larger sizes is on the rise again as an

alternative to clearing large amounts

with algos. On the payments side of

the smartTrade business we see banks

being more competitive when pricing

cross border payments in an attempt

to provide a better all-round solution

for clients not just hedging risk but

also paying bills.”

Next generation technologies such

as artificial intelligence (AI) and

machine learning (ML) are also playing

their part in enabling FX liquidity

management providers to develop

more precise and dynamic tools. While

a number of providers are only a few

years into the release of their AI-driven

services and tools, they are already

ahead of the conservative approach

taken by banks when it comes to

offering automated pricing controls,

says Stead.

“Our clients are very happy to

see us investing heavily in such

technologies but generally they see

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LIQUIDITY MANAGEMENT

What’s driving the need for more innovation in FX liquidity management?

“A lot of liquidity management is about understanding your

goals and monitoring your liquidity over time to make sure that

each client’s goal is met.”

John Crouch

more immediate opportunities in

other areas such as post trade service,

increasing general automation, higher

levels of internalisation and new

services such as options,” says Stead.

“Where we do see most interest is in

terms of allowing clients to use our

inbuilt algos to configure automated

risk book sensitive skews to selected

clients or groups. By combining

various algos in the platform many

clients have been able to raise their

internalisation rates, gain more flow

against their peers and monetise their

flows more efficiently than before.”

There has also been an evolution in

the relationship between FX liquidity

providers and consumers, says

Stead. “People are more aware of

the multifaceted and interconnected

nature of the market than ever before.

A bank is generally both a maker

(provider) and a taker (consumer). If

regulations and balance sheet allows,

they have many more opportunities to

monetise their flows than ever before

thanks to technologies provided by

vendors,” he says.

“They are also aware of how their

actions may impact the flows they

receive and how to educate their own

clients to behave when interacting

with them. There will always be those

who think that they can get away

with double hitting liquidity providers

or trying to surreptitiously sweep a full

amount stream but they are quickly

caught for the most part,” says Stead.

When it comes to selecting FX

liquidity providers the volumes do

matter, says Stead. But it is a more

multifaceted issue than simply scale.

“There is plenty of academic research

that where there is an asymmetry

of information in the FX market

participants who have access to more

flows have a better understanding to

the true value and direction of any

given currency, or to put in in a less

academic phrasing clearly size does

matter!” says Stead.

“But this is a multifaceted market and

there are many other factors. An LP

will often have a holistic relationship

with their clients. FX spot, the most

competitive product, will be just

one product transacted with clients.

Maker LPs that can offer multiple

services for their clients will have more

chances to retain clients’ business

and when they offer benefits that go

beyond a simple haircut on an already

tight spread,” says Stead.

While the vision for next-generation

FX liquidity management includes AIdriven

intelligence, real-time visibility,

and seamless multi-venue integration,

the reality is that widespread

adoption within banks may be more

gradual, says Stead. “Recognising the

inherent complexities and regulatory

hurdles, banks, traditionally slow

to embrace new technologies,

will likely proceed with cautious

implementation. However, vendors

are poised to play a crucial role,

actively exploring and supporting

these advancements. They will provide

adaptable solutions, bridging the gap

between cutting-edge technology and

banks’ operational realities, offering

modular deployments and progressive

integration of AI, enhanced analytics,

and streamlined connectivity,” says

Stead.

Furthermore, the landscape will see

a blending of traditional FX liquidity

with emerging sources, such as FX

futures, which are gaining traction

as a valuable component of liquidity

management strategies, says Stead.

“Crucially, we anticipate a significant

intensification of competition for

FX flows, particularly if peer-to-peer

buyside matching gains momentum.

This shift could lead to a scenario

where certain takers are willing to

pay a premium for liquidity streams

that are not mined for information

or used to train data models, seeking

to preserve their trading strategies

and reduce potential information

leakage. This dynamic will necessitate

advanced tools and services that

can facilitate access to diverse, and

potentially more discreet, liquidity

pools, even if full transformation

takes longer than initially predicted,”

says Stead.

MEETING CLIENTS’ GOALS

Liquidity management in FX has

become a multi-faceted issue,

according to John Crouch, founder

and CEO of Ideal, a provider of

liquidity management and other

services for institutional trading firms.

“The goal is to create a bespoke

experience because clients have

different credit profiles and some are

natural liquidity takers vs makers,”

says Crouch. “A lot of liquidity

management is about understanding

your goals and monitoring your

liquidity over time to make sure that

each client’s goal is met.”

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What’s driving the need for more innovation in FX liquidity management?

LIQUIDITY MANAGEMENT

The relationship between liquidity providers and their clients is shifting from a simple transactional model to a more data-driven, collaborative partnership

Despite his technical background,

the development of the liquidity

management service has made

Crouch a stronger believer in the value

of human relationships. “Ultimately it

is people that will state problems with

your liquidity or your service.”

The demand for bespoke liquidity

management was always there but

the tools to deliver it were not always

available, says Crouch. “In addition,

market participants’ needs change.

For example, when a new head of FX

comes in, the strategy might change

– more internalisation for example.

Some of those demands might be

difficult to deliver but they have

become easier to articulate,” he says.

As an example of how liquidity

demands change, the early 2000s and

the birth of e-trading for FX saw a

number of firms look to drive volume

above all else – sacrificing profitability

in order to become top of the trading

charts. However, this eventually

changed when banks realised they

had to make money. Similarly, ECNs

began to limit access to some high

frequency traders because it was

costing them money.

The development of tools has

also made the relationship more

quantitative than qualitative, says

Crouch. “In the old days, when

all trading was phone-based, the

feedback loop was based on picking

up the phone and hearing a client say

‘You suck!’. But now the conversations

are based around data on spreads or

similar actionable insights.”

“Our tools bring more objectivity

to this conversation and elevate the

relationship between liquidity makers

and takers. We have seen this dynamic

across all asset classes,” says Crouch.

“So in this way, tools have made the

relationship more important. Both

makers and takers are talking the

same language based on common

standards for discussing metrics. It is

no longer possible to be blind to the

metrics.”

Crouch is also concerned about

the role of AI and ML. “We use the

technology to some extent and there

are a lot of benefits but also a lot of

things to consider. My goal is to help

the clients and if AI can help me get

to the answer faster, that’s great,” he

says.

But when it comes to the cons, there

are three that stand out, says Crouch

– privacy, privacy and privacy. “We are

really thoughtful about clients’ data

– it belongs to them and it has to be

strictly private. We don’t comingle

clients’ data and if they want that,

they will have to go somewhere else.

Respecting our clients’ privacy is one

of our guiding principles and we have

designed our architecture around it.”

When it comes to the next

developments in liquidity

management, Crouch talks about

the monitoring and inclusion of more

data and not just spreads and trading

costs. For example, Ideal is evolving

analytics for operational risk.

28 MARCH 2025 e-FOREX


“LPs need to implement integrated digital solutions and robust

operational strategies that keep latency low and optimise

execution performance for all clients.”

Paul Jackson

“So far clients have prioritised

profitability,” he says. However,

awareness of the importance of socalled

‘operational alpha’ is growing

among FX participants. For example, a

company may be sending many orders

that are off market and/or short-lived

that have little chance of matching,

but utilise compute and network

resources.

“Ultimately it is about asking the right

questions and then finding the best

way to solve them. By bringing data

to the discussion, we’re able to get to

the answers quickly” says Crouch.

TECHNICAL INNOVATION

According to Paul Jackson, joint

head of sales EU, UK & LATAM,

for Finalto, technical innovation

has made liquidity management

more competitive. “Advances in

technology mean that orders can

be processed more quickly, over a

broader geographic area. LPs need to

implement integrated digital solutions

and robust operational strategies

that keep latency low and optimise

execution performance for all clients.”

says Jackson.

“There’s also pressure from rising

costs. Technology and operational

costs are rising in a context of

FX yields remaining relatively low

comparative to other asset classes.

This dynamic makes the space

even more competitive. The core

goal has to be maintaining the

highest standards of execution,

with responsible risk controls, while

remaining competitive.”

A combination of regulatory and competitive pricing pressures are redefining participants’ roles in terms of

liquidity management

Leading liquidity providers are

innovating and growing by entering

new markets, continuing to develop

enhanced tools, and providing service

that better suits clients’ needs, says

Jackson. “Practically speaking, in our

experience, that involves expanding

into emerging markets (Mena,

LatAm, South Africa), building risk

applications and enhanced flow

analytics, and offering customised

liquidity and sophisticated execution

logic.”

At the same time, clients are

becoming more sophisticated,

supported by advances in technology,

and with increased market access,

says Jackson. This is fuelling the

demand for customised liquidity.

“Their needs and expectations are

highly variable, and liquidity providers

need to be agile to take on different

types of flow. For example, the needs

of a retail broker might be very

different to a systematic hedge fund.

A ‘one size fits all’ approach is no

longer adequate,” says Jackson.

Relationships between FX liquidity

providers and liquidity consumers are

also changing, says Jackson. “Over

the last decade, brokers started mass

aggregating to compress spreads and

compete against peers. Increased

costs have seen brokers pulling back

to work closer with select LPs that

can offer a broader suite of products

and a more cost-effective approach

by centralising risk. Cost, product,

service and security are key deciding

factors for liquidity consumers.

Liquidity providers need to continue

investing in core technology to remain

competitive and provide the highest

levels of service. While speed remains

crucial, clients also increasingly expect

technologies that offer richer data and

help optimise their own operations,

including advanced analytics and

automation,” he concludes.

MARCH 2025 e-FOREX 29


Unlocking the power of granular data

to transform the Forward FX market:

Insights from New Change FX

By Paul Lambert, CEO of New Change FX

MARKET INSIGHTS

Paul Lambert

“Transparency is not the same as

looking at data; it is the ability to

see and understand data in context,”

according to leadership expert Simon

Sinek. We agree with Sinek and believe

the evolution of the foreign exchange

market is inextricably linked to the

availability of accurate, unbiased and

granular data.

The landscape of foreign exchange

trading has undergone a seismic shift,

particularly with the rise of electronic

trading platforms that dominate the

spot market. Billions of price points

are streamed daily across various

platforms, thanks to the dual engines

of regulation and technological

innovation. Large fund managers are

now mandated to demonstrate “best

execution,” leading them to take a

more comprehensive view of their

trading relationships and value-added

services. Regulatory requirements have

also compelled large asset managers

to engage in transaction cost analysis

(TCA) to validate their trading

practices.

Yet, despite these advancements,

a substantial portion of foreign

exchange trades remains manual,

especially in the forward market

where trades are usually executed into

“broken dates.” If the electronification

of spot foreign exchange represented

a monumental leap akin to landing

on the moon, the forward market’s

electronification resembles a journey

to Mars—inevitable, yet fraught with

challenges and uncharted territory.

The complexities of the forward

market stem from various factors,

notably the approximately 250 trading

days per year for each currency pair

and the escalating significance of

credit components as trade durations

increase. This complexity complicates

the provision of accurate pricing that

accommodates all participants. While

some electronic platforms have begun

streaming “standard tenors” like one

week or one month, the reality is that

most trades do not go into standard

tenors.

Futures markets have made strides by

providing electronic solutions for future

FX trades, effectively addressing credit

issues through margin management.

However, these exchanges face

the same limitations as those

focusing solely on standard tenors,

neglecting the vast utility offered by a

comprehensive range of dates.

Despite these barriers, progress is on

the horizon, and at New Change FX

(NCFX), we believe the crux of the

forward FX market’s evolution lies

in data. Experience in other sectors

demonstrates that the fusion of

advanced technologies—such as

Artificial Intelligence (AI) and Machine

Learning (ML)—with robust data can

catalyse substantial progress.

Historically, data in the forward

foreign exchange arena has been

fundamentally flawed. The predominant

focus on standard tenors, with linear

interpolation between those dates, fails

to capture the necessary granularity.

This oversight results in a disconnect

between theoretical pricing and the

realities faced by market makers.

NCFX has pioneered the development

of granular and “neutral” forward

curves, a breakthrough that we believe

will significantly enhance market

functionality.

30 MARCH 2025 e-FOREX


MARKET INSIGHTS

The utility of NCFX’s Forwards365

curve is profound. It not only

provides a benchmark for post-trade

evaluation but also signals pretrade

pricing discrepancies. As large

fund managers continue to grapple

with TCA, many had reduced this

vital process to a mere compliance

exercise. This is understandable;

if they are assessing performance

against flawed data, the value of such

assessments diminishes. Knowledge

of the real neutral curve empowers

traders to make informed decisions,

enhancing the integrity of their

trading strategies.

Moreover, the forward FX market’s

intricacies mean that liquidity

providers (LPs) often manage their risk

by clearing through standard tenors,

relying on these data points for

visibility into broader market pricing.

However, challenges remain in them

demonstrating their axes in the

broken dates where they may want

to reflect either their market view or

inventory management post-client

facilitation. A transparent neutral

curve enables traders to navigate this

landscape more effectively, optimising

pricing strategies and reducing

market impact.

The Gobal FX Code has emphasized the necessity for

independent data to guide optimal trading outcomes

EARLY ADOPTERS

Some of the earliest adopters of

our data include prominent asset

managers and sophisticated central

banks. Their feedback underscores

significant advantages, such as

improved date selection for rolling

trades and the ability to discern

genuine market value in dealer quotes.

One asset manager likened accessing

our data to putting on glasses—

suddenly, the market came into focus.

Eric Brown FX trader at T. Rowe Price

says “NCFX Forwards365 provides

an independent view of the curve to

aide in pre-trade price discovery and

optimal date selection when rolling

positions. Their data adds value in our

process and helps give us increasing

clarity into where the market is

trading.”

Furthermore, the knowledge of the

neutral curve can be used to help

mitigate the “winner’s curse” which

occurs when the price taker discloses

their trading intentions to too many

losing (LPs) meaning the winning LP

now holds a trade that everyone else

knows about. When asset managers

leverage this granular data, they can

strategically engage with fewer LPs,

enabling them to offer better pricing.

This dynamic fosters an environment

where both asset managers and LPs

can operate more efficiently, achieving

mutual benefits.

Banks, including those in marketmaking

roles, require independent

data for some of the same

reasons. Understanding where

asset managers perceive value in

the market enables LPs to offer

competitive pricing while managing

their own risk exposure. With cost

pressures compelling LPs to do more

with fewer traders, maintaining

precise pricing on single-dealer

platforms becomes increasingly

critical and an independent curve

can provide a valuable oversight.

Eric Brown

The Global FX Code has emphasized

the necessity for independent data

to guide optimal trading outcomes.

Independence is paramount; it is

challenging to maintain objectivity

when vested interests are at play.

NCFX’s benchmark rates draw from

a wide market spectrum, ensuring

transparency and neutrality—principles

at the core of our mission.

Looking ahead, we anticipate

two pivotal developments: the

establishment of a more sophisticated

feedback loop between trading

activity and pre/post-trade analytics,

and a significant leap toward the

electronification of the forward

market. The former only makes sense

if the data driving the process is

independent and accurate. Anything

less than this will open the process to

inefficiencies and abuse. The latter

will hinge on illuminating all trading

dates, with the neutral curve as a vital

component in drawing market interest.

In summary, the evolution of the

forward foreign exchange market is

inextricably linked to the availability

of accurate, granular data. New

Change FX stands at the forefront

of this transformation, committed to

providing the insights necessary for

market participants to navigate an

increasingly complex landscape with

confidence.

MARCH 2025 e-FOREX 31


Why data-driven

decision making will

shape the future of

FX trading

By Vivek Shankar

(discovery, creation, distribution,

of data application has reached

trading, post-trade, risk management,

unprecedented levels. “Trading desks

and TCA). The more the data becomes

are using data to optimise pricing

available, the more knowledge and

and execution strategies in more and

SPECIAL REPORT

Vivek Shankar

Automation and electronification

have gone from nice-to-haves to

derived activity (distribution, trading,

TCA) it will generate.”

What are the benefits of data-driven

decision-making in FX and how can

firms overcome the common hurdles

associated with these processes? Let’s

take a look.

TRANSFORMING FX THROUGH

STRATEGIC DATA USE

The landscape of electronic FX trading

continues to evolve dramatically, with

data emerging as both catalyst and

more innovative ways,” he observes.

“Data enables clients to optimise

risk management strategies across

customer groups, instruments or

entities, while also providing insights

into trading patterns.”

The strategic value of high-quality

data becomes particularly evident

when examining execution outcomes.

Paul Lambert, Chief Executive Officer

at New Change FX, emphasises this

critical connection.

essentials in FX. While firms can access

several solutions providers that help

them automate trade processes,

many initiatives grind to a halt due

to a fundamental issue: data. To be

precise, the issues surrounding FX

data are complex and pose significant

hurdles for firms looking to ramp up

automation. Bart Joris, Head of FX

Sell-Side trading, Customer Proposition

Data & Analytics, LSEG, underscores

data’s importance.

cornerstone of this transformation.

Industry experts point to a virtuous

cycle where increased electronification

generates more data, which in turn

enables further automation and market

sophistication.

“Once electronification starts, it only

accelerates the volume and accuracy of

the data in the FX market,” notes Joris,

highlighting how this self-reinforcing

process is reshaping market structures.

“Without robust data, the ability to

fully automate processes remains

constrained,” Lambert states. “By

leveraging historical transaction data,

benchmark rates, and transparent

execution costs, firms can embed best

execution practices directly into their

trading strategies.”

This integration creates tangible

competitive advantages, allowing firms

to automate with confidence. “Leading

market participants increasingly

Image by Shutterstock

“Transparent access to data is the

key to any electronification of the FX

market,” he says. “The data is key to

the lifecycle of any trading activity

This evolution extends far beyond

simple automation. As Stephen Totten,

Director of Quantitative Analysis at

oneZero, explains, the granularity

integrate benchmark data into their

execution frameworks,” Lambert

continues, “allowing them to automate

smaller trades with confidence,

32 MARCH 2025 e-FOREX


SPECIAL REPORT

MARCH 2025 e-FOREX 33


Why data-driven decision making will shape the future of FX trading

“The more the data becomes available, the more knowledge

and derived activity (distribution, trading, TCA) it will

generate.”

adopting data-centric operational

models gain advantages across the

entire trading lifecycle, creating

sustainable competitive edges in an

increasingly automated marketplace.

“Manual workflows are not only

costly but also susceptible to errors,

whereas automation enhances

accuracy and streamlines execution.

However, automation without proper

oversight can lead to the repetition of

suboptimal outcomes,” he cautions.

“Independent benchmark data serves

as a critical safeguard, providing the

necessary checks and balances.”

SPECIAL REPORT

Bart Joris

knowing they are operating at or near

continuous benchmark rates.”

The resulting operational efficiencies

enable strategic resource reallocation,

with Lydia Solinski, Managing Director,

Global Head of Liquidity, Data &

Business Information, pointing to the

market differentiation this creates.

“Data is revolutionizing electronic FX

trading by boosting speed, efficiency

and decision-making,” Solinski

explains. “It differentiates FX market

participants by enabling those with

advanced analytics and real-time

insights to execute faster, more

informed trades.”

The technological foundation

supporting these advancements

continues to evolve as well.

“Central to all of this is cuttingedge

technology, like Artificial

Intelligence, which is driving

innovation in FX trading with data

acting as the essential fuel,” Solinski

adds, underscoring how data

quality increasingly determines the

effectiveness of automated workflows.

Building on the transformative role

of data in electronic FX trading, firms

“A data-centric approach can help

you to find and optimize your trading

outcomes,” explains Joris. “It is the

learning cycle which gives you the

competitive edge.” This continuous

feedback loop transforms raw

transaction data into actionable

intelligence, enabling firms to “create a

coherent price construction, determine

market conditions and reassess this to

build even better trading behaviours

for the future.”

The evolution from basic metrics

to sophisticated analysis has

fundamentally changed how trading

desks evaluate performance. Totten

articulates this shift in management

perspective. “Traditionally, desk heads

relied on end-of-day PnL and traded

volumes to gauge business success;

however, with a sophisticated data

platform, a desk head can analyse

profitability at the level of individual

clients, currency pairs, trading and

execution styles,” he notes.

This granular insight allows firms to

“assess performance across different

market conditions, including highvolatility

events and quieter periods.”

INDEPENDENT DATA

As firms accelerate automation

initiatives, Lambert emphasises the

critical role of independent data in

maintaining operational integrity.

Beyond risk management, proper data

utilisation directly impacts financial

performance through optimized capital

allocation. “By ensuring that positions

are marked to market correctly—

particularly in the forward foreign

exchange market—firms can minimize

profit and loss volatility and optimize

capital allocation,” Lambert explains.

“A precise mark-to-market process

reduces unnecessary capital reserves

against positions, enhancing overall

liquidity and financial stability.”

The client relationship dimension

represents another strategic advantage,

with Solinski highlighting how data

transparency builds trust.

“A data-centric approach offers

significant strategic business

advantages for FX operations.

First, it helps meet the growing

Stephen Totten

“Data enables clients to optimise risk management strategies across

customer groups, instruments or entities, while also providing

insights into trading patterns.”

34 MARCH 2025 e-FOREX


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SPECIAL REPORT

Why data-driven decision making will shape the future of FX trading

“By leveraging historical transaction data, benchmark rates,

and transparent execution costs, firms can embed best

execution practices directly into their trading strategies.”

Paul Lambert

requirements of best execution by

enhancing transparency and trade

outcomes,” she observes. “Data also

drives transparency and integrity into

the heart of FX relationships, and

promotes a culture of truly treating

clients fairly.”

Looking forward, Solinski points to

emerging technologies that will further

enhance data utilization. “We are now

investing in ML and AI technologies

to ensure that data drives Liquidity

optimisation and ultimately insight

into how to best place trades in the FX

market,” she notes, underscoring the

ongoing evolution of data’s strategic

value.

Data-centric approaches create

competitive advantages, particularly in

execution quality and benchmarking

performance. Lambert emphasises

the fundamental role of independent

reference points in this process.

“Leading firms increasingly rely on

independent benchmark data to

ensure execution quality and optimize

trading strategies rather than use data

that provides a partial view of available

pricing,” he explains. “By embedding

independent data into their execution

frameworks, firms can confidently

automate smaller trades while focusing

human expertise on larger, more

complex transactions.”

This capability delivers tangible

benefits beyond simple automation.

“Access to independent, continuous

pricing ensures greater visibility into

spreads, liquidity, and execution costs,”

Lambert adds. “This transparency

reduces information asymmetry,

enabling price takers to make more

informed decisions and liquidity

Firms adopting data-centric operational models gain advantages across the entire trading lifecycle

providers to offer fairer pricing.”

The multidimensional nature of

execution quality extends well beyond

simplistic price metrics, as Totten points

out. “It’s very easy to just assume

best execution equals best price, but

in today’s market more sophisticated

providers consider a much broader set

of factors,” he notes. “To truly optimise

pricing, traders must assess the

potential market impact of their trades,

taking into account variables such

as time of day, liquidity, information

leakage, and whether one of their LPs

has an axe or interest.”

This nuanced perspective aligns with

Joris’s observation about the varied

interpretations of best execution across

the industry. “Best execution has

been a major buzzword in FX, but it

does not mean the same to all,” Joris

explains. “Though one point is clear,

best execution can only happen based

on the data used and what is available

to compare it too.” The quality, depth,

and accessibility of data therefore

become critical factors in execution

optimization.

This growing emphasis on

independent market data is evident in

the increased adoption of specialised

datasets, as Lisa Danino-Lewis, Chief

Growth Officer, CLS notes: “We have

seen a growth in the take-up of our

CLSMarketData sets. This is indicative

of a wider market infrastructure

trend from the front office, which

is increasingly leveraging alternative

sources of trade data to support

activities across a broad range of

functions. CLSMarketData is derived

from the largest single source of FX

executed data available to the market.

Our data sets – FX Volumes, FX Flow,

FX Outstanding and FX Pricing –

provide quality insights both on a

timely and historical basis. Within

buy-side firms, FX Volume and FX

Flow datasets are utilised by portfolio

36 MARCH 2025 e-FOREX


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SPECIAL REPORT

Why data-driven decision making will shape the future of FX trading

“We have seen a growth in the take-up of our CLSMarketData sets.”

Lisa Danino-Lewis

managers as a component into

systematic trading models, and are

being used to improve transparency in

market activity.”

Despite progress in data utilization,

significant challenges remain in

certain market segments, as Solinski

highlights. “Swaps and Forwards are

the last bastion of opacity in FX, where

quality streaming data is very rare,” she

notes. “This will constrain the evolution

of automation in the Swap and FWD

space. The data must be there for

automation and best execution to take

place.”

Beyond availability, Yusuf Nurbhai,

Head of BestX emphasises that data

must be actionable and tailored to

specific client requirements. “Data and

transparency alone will not help the

buy side in achieving best execution

outcomes as each client’s trading style

and best execution policy are unique,”

he observes. “It is important to create

a solution that allows clients to set

their preferences for the analysis, with

the ability to make those insights

actionable at point of execution rather

than providing only a post-trade

evaluation of performance.”

This forward-looking approach

represents an important evolution

beyond traditional transaction cost

analysis. “Historically, TCA has always

been a backward-looking process,”

Nurbhai adds. “Initiatives like our

BestXecutor, harnesses historical and

live data, delivering a forward-looking

approach. Such tools allow the client to

make more informed decisions right at

the point of execution.”

CONFRONTING ACCESS,

VOLUME, AND LEGACY

CHALLENGES

The evolution toward data-driven FX

operations faces several significant

hurdles that firms must overcome

to fully realize the benefits of

electronification. The issue of data

availability varies significantly across

FX market segments. While spot

markets have achieved relatively high

levels of transparency, other product

areas remain less accessible, affecting

pricing quality and execution

efficiency.

“Data is not inherently democratic, as

those with access to high-quality data

often protect it within the solutions

they offer,” explains Yusuf Nurbhai,

Head of BestX. “Independent TCA

venues like our BestX® have the

potential to democratize data, making

it accessible to everyone.”

This democratization process is

gathering momentum through a

combination of regulatory pressure

and market-driven solutions, as

Lambert points out. “Regulators

are increasingly focused on

making pricing data accessible,

promoting transparency and

levelling the playing field,” he notes.

“Frameworks like MiFID II and the

FX Global Code mandate fair data

access, which helps reduce search

costs and ensures more informed

decision-making.”

The consolidation of pricing

information represents another crucial

step toward greater accessibility.

“Aggregating pricing from multiple

venues reduces the complexity of

finding true market rates, allowing

market participants to access accurate,

up-to-date data in one place,” Lambert

adds.

Significantly, this approach directly

addresses cost concerns: “By

integrating independent data

directly into trading platforms, firms

eliminate costly technical integrations.

This enhances execution efficiency,

reduces infrastructure costs, and

allows participants to access real-time

data seamlessly within their existing

workflows.”

As data becomes more commoditized,

economics will also shift. “As data

becomes more commoditized, its price

is expected to decrease, although the

cost of Swap and FWD data will remain

high due to its limited availability,”

Solinski observes, highlighting the

persistent premium on less accessible

market segments.

As data volumes expand, firms face

mounting challenges in storage,

transport, and processing. These

technical considerations have

significant implications for operational

efficiency and cost management.

“These days I see technology as an

enabler rather than a restriction to

the growth of data. Times where vast

amounts of data were troublesome

to handle are over,” observes Joris.

However, he cautions that “it is more

a discussion on what data is relevant

for the use cases, and this will have

greater impact on the success factor as

more data does not always transgress

into a better outcome. Be forensic on

the data needs as data becomes one

of the highest cost factors in your

ecosystem.”

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SPECIAL REPORT

Why data-driven decision making will shape the future of FX trading

“Data is revolutionizing electronic FX trading by boosting

speed, efficiency and decision-making,”

Lydia Solinski

This selective approach to data

becomes particularly important

during periods of market volatility, as

Totten highlights. “The most valuable

insights tend to emerge during

periods of market stress - precisely

when liquidity providers generate the

highest volume of data,” he explains.

“Just as a desk head must ensure

their trading desk operates well under

stress, they must also ensure that their

data platform can cope with large

peaks, both ensuring that there are

no gaps or anomalous data, and also

that the data is processed rapidly for

quants and traders to do any required

investigations or optimisations.”

The technical solutions to these

challenges continue to evolve, with

Lambert noting several strategic

approaches. “As data volumes increase,

traditional storage solutions become

costly and inefficient,” he explains.

“Cloud storage offers scalability,

allowing us to expand capacity as

needed. By using tiered storage, we

can differentiate between frequently

accessed and archived data, optimizing

storage costs.”

The transport of massive data volumes

presents its own set of challenges.

“The volume of data we consume

could introduce latency. So we use

data compression to improve transport

efficiency, while ensuring compliance

with data governance regulations,”

Lambert adds. “By providing an

integrated and diverse data set from

various platforms we can reduce our

customers’ data requirements and

provide them the data using reliable

electronic connections and using APIs

to ensure the smooth integration

across systems.”

Beyond storage considerations, data

security and analysis capabilities have

become increasingly critical. “At State

Street, we are heavily focused on

securitization of data, ensuring that

the right data is delivered to the right

hands,” Solinski emphasises.

Perhaps the most persistent challenge

in FX data utilization stems from the

fragmentation between different

market segments, where varying levels

of electronification create distinct data

ecosystems.

“The limitation of the available data

is not directly related to the data

distribution capabilities, as this is

the same for any trading paradigm,

though different trading paradigms

will lead to different availability,” Joris

explains. “Let us take swaps, on the

interbank markets a lot more factors

are more pronounced which influences

the price creation in comparison to

spot. This ranges from dates (balance

sheet driven), credit (client), skew

(positions), adjustment factors on

terms and ccy (risk profile). So, it is

not easy to determine a central tape

of pricing data as out of trading data

there is always a different angle.”

This complexity is compounded by

legacy system limitations, as Lambert

notes. “Many institutions still rely on

legacy systems that are difficult to

modify. These rigid structures make

integrating diverse data sources

challenging.”

However, solutions exist: “Upgrading

legacy systems can be overwhelming,

but working with third-party

technology providers helps firms

integrate external data sources

efficiently. To overcome data silos,

firms must adopt more agile, scalable

data ecosystems that support diverse

data sources and advanced analytics.”

Totten points to an encouraging

trend toward greater electronification

across previously opaque market

segments. “While it’s true that certain

products suffer from poor data quality,

this is largely tied to their level of

electronification - a trend that will

continue to improve over time,” he

observes. “Market understanding and

expertise is key, as one needs to know

when and when it’s not appropriate to

use certain data sets, and the potential

data quality issues that come with

them.”

Banks occupy a unique position in this

ecosystem, with potential advantages

in certain market segments. “Banks

have an added advantage in access

to swap and FWD pricing,” Solinski

explains. “While they do have the

information, they are investing in

their architecture to stream these

quotes on an ESP basis. However, this

investment has multiple benefits as

it will ultimately underpin the future

streaming environment that Swaps

and FWDs will eventually evolve

towards.”

This evolution toward more

transparent and integrated data

systems across all FX market segments

represents the next frontier in

market development. “Platforms like

GlobalLINK are uniquely positioned

as they host both buy- and sell-side

data,” Nurbhai notes. “Due to their

40 MARCH 2025 e-FOREX


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03/31/2026

MARCH 2025 e-FOREX 41


Why data-driven decision making will shape the future of FX trading

disjointed.”

SPECIAL REPORT

Artificial intelligence and machine learning are reshaping how firms extract value from their information assets

independence, TCA venues have the

potential to serve as key vehicles for

advancing data democratization for

the buy side.”

The path forward requires both

technological innovation and strategic

partnerships. As Joris concludes, “The

need for a clean neutral data curve

without these influences is the key to

price creation. This is where a lot of

work is needed to create such datasets

either from participants or from

trading venues.”

BUILDING THE DATA-DRIVEN FX

ORGANISATION

The journey toward becoming a datacentric

institution involves more than

just technology upgrades. It requires

fundamental shifts in organisational

culture, processes, and skills. As FX

market participants navigate this

transformation, they must balance

strategic vision with practical

implementation steps to maximize the

value of their data assets.

“What will drive the use is traders

adopting the mindset that data and

electronification is there to help and

can achieve better outcomes,” Joris

explains. “The shift from execution

to risk management, this will be the

unlocking factor to a data-centric

operation.”

This mindset transformation must

extend throughout the organisation,

affecting how different functions

approach their roles. Totten highlights

how this reshapes incentive structures

and responsibilities. “Traders can

look at market microstructure and

execution strategies to work out how

to better optimise their pricing and

hedging. Salespeople, rather than

being incentivised purely on volume,

can be incentivized on PnL, and must

thus understand what makes certain

types of flow good or bad,” he

observes.

This comprehensive shift “is not a

simple transformation and will likely

require an organisation to either hire

specialised staff, or work closely with a

business aligned vendor.”

The path toward data-centricity

begins with strategic commitment, as

Lambert notes. “Firms that successfully

use data have in our experience taken

a strategic decision that data will

support every decision they make,”

he states. “Some parts of foreign

exchange have a long history of being

data driven, such as quantitative

trading strategies, while for others the

use of data often remains clunky and

This organisational transformation

requires structured governance and

clear accountability, according to

Solinski. “We have restructured our

data to be centrally located, enabling

us to leverage it in a strategic and

powerful way,” she explains. “We

have established protocols that are

strictly followed to ensure we use only

permitted data. This is important, as

data comes with associated rights.

Additionally, we have designated

owners for data technology and

functions, ensuring accountability in

how and when data is utilized.”

The implementation of these strategic

visions demands practical steps for

normalising and structuring data

flows. While many firms are turning

to external partners for technical

infrastructure, Totten cautions about

potential tradeoffs. “Building and

maintaining adapters to venues is

something that more and more

institutions are outsourcing to vendors

that can deliver the critical low latency

and infrastructure management

requirements they have,” he notes.

“However, normalisation can lead to

loss of some critical venue specific

information, such as if an ECN is

tagging prices in a certain way to allow

for more optimised execution.”

The fragmentation of data sources

within organisations presents another

significant challenge. “We still see

disjointed structures within trading

firms where the unfiltered exhaust of

trading or broking activity is offered

up as a source of market data,”

Lambert observes. “Sometimes errors

and omissions can only be seen when

checked against another source.”

A centralised approach to data

organisation emerges as a crucial

element for maximizing value. “Trading

firms should implement standardized

tools to ensure their transaction and

42 MARCH 2025 e-FOREX


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SPECIAL REPORT

Why data-driven decision making will shape the future of FX trading

“Data is not inherently democratic, as those with access to highquality

data often protect it within the solutions they offer”

Yusuf Nurbhai

market data are clean, structured

and optimized,” Solinski explains.

“We have centralized this data,

mapping values of a single trade

through the whole trade cycle, and

structured technology around this

data to create efficiency at every

point of the trade.”

Realistic timeframes for these

transformations vary widely

depending on organisational

factors, but external partnerships

can accelerate progress. “Managing

and consuming data takes skill and

commitment, and its complexities

should not be underestimated,”

Lambert notes. “Working with

experienced and customer focused

partners can certainly reduce the

timeframe and costs of developing a

successful data strategy.”

While the investment requirements

are substantial, the market

increasingly offers accessible paths

to data transformation. “There are

however third party data technology

providers who democratize access to

sophisticated use of data,” Solinski

concludes. “We champion these

as we share the same strategy- to

deliver best trade outcomes for FX

market participants.”

THE VALUE OF SPECIALISED

EXPERTISE AND INTUITIVE

TOOLS

The evolution of FX data management

platforms has profoundly transformed

how market participants interact

with and extract value from their

data. These next-generation solutions

combine sophisticated analytical

capabilities with increasingly intuitive

user interfaces, making powerful data

science accessible to non-technical

users.

“There was an old belief that traders

would evolve into ‘fincoders’, with

the ability to write code and create

their own models and data sets,” Joris

observes. “This is rapidly changing,

and we now have LLMs and AI

enabling traders to skip the code and

just use natural language to get to the

required information. This is a fastmoving

market and will be the future

in making it more intuitive to the end

consumers than direct programming

skills.”

This shift toward natural language

interfaces represents just one aspect of

how solution providers are reimagining

user experience. Totten highlights

how deep workflow integration has

become a central focus. “Our analytics

are designed with this in mind,

ensuring that users have seamless

access to critical information,” he

explains. “For example, ahead of a

customer call, they can view all key

data alongside the most relevant drilldowns

to quickly address customer

inquiries. Additionally, our platform

highlights data points that may reveal

opportunities to expand share of

wallet, empowering users to make

informed, strategic decisions with

ease.”

The effectiveness of these front-end

innovations remains intrinsically linked

to robust back-end data management

practices. “Our experience is that

backend data management and

frontend tools go hand in hand,”

Lambert notes. “If your data is not

stored, organised and consolidated

efficiently, then it’s very hard to

build good front-end tools that work

well. But if you get both your data

management and front-end tools

right then the outcomes can be

spectacular.”

When selecting data management

partners, domain expertise emerges

as a crucial differentiator. The

unique complexities of FX markets

demand specialised knowledge that

goes beyond general data science

capabilities.

“FX domain knowledge remains a key

factor as understanding the market, FX

data structure, impact and correctness

is not just a numbers game,” Joris

explains. “Real value lies in the firms

which can make the leap between

what is the deep domain knowledge

of a system code and what is the

finesse of the FX market.”

This domain expertise becomes

particularly valuable when firms are

navigating business transformation.

“Many make the error where they

try to implement a manual process

into an electronic system, but this

defeats the purpose and the value

of electronification,” Joris adds.

“Electronification means trading

model changes on the client, sales and

trading desks. Partnering with people

who can help you to do this is key to

its success.”

The advantages of specialised partners

extend beyond implementation

support to ongoing innovation

and insight generation. “There are

many reasons for working with

44 MARCH 2025 e-FOREX


SPECIAL REPORT

sophisticated vendors in this space,

including the setup and management

of a robust data pipeline, the ongoing

development of business focussed

analytics, and our work on increasingly

precise, actionable outcomes,” Totten

notes.

This commitment to specialised

expertise drives strategic investment

decisions. “oneZero’s recent acquisition

of Autochartist - a leader in marketdata

driven technical analysis and

content is a demonstration of our belief

and commitment to the real value that

analytics can bring to businesses,”

Totten adds.

The interpretation of data presents

another area where domain expertise

proves invaluable. “We see many firms

offering reams of data, but with no

relevant expertise in the underlying

market, it is difficult for those firms

to ensure they are handling the data

correctly or to offer much-needed

value-added services like advanced

analytics using that data,” Lambert

observes.

“It is important therefore not just to get

the raw data, but to have confidence

that it provides the information you

need and expect and to be able to

query the context.”

Beyond technical capabilities and

market knowledge, institutional

stability and regulatory compliance

represent additional considerations

when selecting data partners. “When

choosing a partner for your data and

trading ambitions, it is important to

collaborate with a trusted partner who

can easily integrate with your existing

ecosystem,” Solinski explains.

“Being part of a Globally Systemically

Important Financial Institution (G-SIFI)

institution, GlobalLINK adheres to

the highest of data protocols in

the industry. There is strict legal

and regulatory framework in place

When selecting data management partners, domain expertise emerges as a crucial differentiator

to protect the use of all data that

transmits across our technologies.”

This foundation of trust becomes

increasingly important as firms entrust

sensitive information to external

partners. “Our technologies are used

by large investment corporations

holding highly sensitive and valuable

information,” Solinski concludes.

“Our investment in technology and

innovative approach will help our clients

move with confidence as their data is

safe and secured.”

THE AI-POWERED FUTURE OF FX

DATA MANAGEMENT

As data management capabilities

continue to evolve in the FX market,

artificial intelligence and machine

learning are reshaping how firms extract

value from their information assets.

Totten highlights this shift from

specialised applications to mainstream

adoption: “Where we’ve seen great

steps forward recently is around the

sophistication of language models.”

This evolution enables more intuitive

data interactions, where “a salesperson

could have an LLM agent listening on

a customer phone call or monitoring

a chat to actively query and produce

relevant reports on the fly, transforming

how trading professionals access and

utilise analytical insights.”

Despite technological advances, the

fundamental principle of data quality

remains paramount. “Having spent

many years building alpha generation

models in foreign exchange, I learnt the

powerful lesson of ‘garbage in garbage

out’,” Lambert emphasises.

This reality underscores that the

sweeping changes that are brought

forward by AI and ML will be most

richly reaped by firms that have the

best understanding of their own data”

and who partner with organisations

providing rich, accurate contextual

information.

The practical implementation of these

technologies is already delivering

concrete benefits across the industry.

As Lambert notes, “At NCFX our data

is already feeding AI and ML tools both

internally and for our clients who are

garnering great understanding of the

environment that they are operating

in.”

As the market continues its data-driven

transformation, organisations that

successfully maintain high-quality data

foundations while embracing new

technological possibilities will capture

the competitive advantages that

AI-enhanced data management can

deliver.

MARCH 2025 e-FOREX 45


Exploiting the raw power of FX data:

A product perspective from

LMAX Exchange

LMAX Exchange offers both market and trade data via multiple connectivity options. We asked Arun

Sundaram, Head of Market Data at the firm, to tell us more about how traders are leveraging data

to optimise their FX trading operations and execution strategies.

PRODUCT PERSPECTIVE

Arun Sundaram

What types of trading firms is

LMAX Exchange providing FX data

for?

LMAX Exchange provides FX data

to a diverse range of firms across

the financial ecosystem. Banks

and financial institutions use it

for pricing, liquidity management,

execution and trade monitoring,

while proprietary trading firms rely

on our firm, high-quality data for

algorithmic and high-frequency

trading. Hedge funds leverage LMAX

Exchange’s real-time and historical

FX data for strategy development,

execution and risk management,

while retail brokers and liquidity

providers redistribute it to enhance

execution quality for retail clients.

With institutional-grade, no-last-look

FX data, LMAX Exchange supports

a wide range of clients, each

using it to power their trading and

investment strategies.

Please give us some examples of

the range of applications that your

market data is being used for.

Our data is used in various ways

across the trading ecosystem and

is a trusted benchmark for pricing

comparisons and execution quality

assessments.

Firms rely on it to develop and

refine quantitative trading

strategies, from arbitrage and

high-frequency trading to AI-driven

models. Data scientists and fintech

firms incorporate it into predictive

models for market forecasting and

automated trading, while brokers

use it to improve execution quality

for retail clients. Quant researchers

use our historical data for back

testing, validating and optimising

their strategies. Risk managers

monitor market conditions, adjust

hedging strategies, and detect price

anomalies, while transaction cost

analysis teams evaluate trading

costs, measure slippage, and refine

execution.

In what sort of ways does the

granularity of LMAX Exchange’s

data empower traders?

We provide full visibility into market

liquidity, giving traders access to depth

of market (DOM) data. This enables

them to see where large orders sit and

how the market absorbs volume. With

up to 1,000 price updates per second,

traders can track liquidity shifts in

real time and refine their strategies

accordingly. Market makers and

liquidity providers can also adjust bid/

ask spreads dynamically based on realtime

order book depth. Additionally,

our historical data offers the same

level of granularity, providing valuable

insights into flow volumes across

various use cases.

What about market impact? What

role does LMAX Exchange’s data

play in managing that?

LMAX Exchange’s data plays a critical

role in managing market impact by

providing anonymised and aggregated

data from the Central Limit Order

Book, including “firm” liquidity order

book depth. This allows traders to view

and analyse liquidity pockets, helping

them execute large orders with

minimal price impact or slippage.

By understanding where liquidity is

46 MARCH 2025 e-FOREX


PRODUCT PERSPECTIVE

We provide full visibility into market liquidity, giving traders access to depth of market (DOM) data

concentrated, traders can make more

informed decisions to minimise their

effect on market prices.

our clients worldwide. Our industryleading

technology is recognised for its

high capacity, robustness, and ability

to deliver ultra-fast performance,

on such price moves can capture, on

average, 85-95% of the subsequent

EUR/USD decline within the next hour.

Our analysis shows that sub-second

What makes LMAX’s ultra-fast

FX market data so unique in the

marketplace?

achieving internal exchange latency

of less than 50 µs. Additionally, we

maintain a 100% exchange uptime

and implement platform releases every

price action contains valuable insights

that enable traders to capitalise on key

monetary events.

Our ultra-fast FX market data is unique

due to direct access to our ‘firm’

and ‘executable’ limit order book

liquidity data, which is updated at a

frequency of 1,000 price updates per

second (1ms). This high-speed access

is available to all clients, regardless

of their size, providing them with an

unparalleled ability to execute trades

and respond to market changes in

real-time. This combination of speed,

transparency, and accessibility sets

LMAX Exchange data apart in the

marketplace.

two weeks to continuously enhance

performance and innovation.

Currency markets manifest price

moves around event dates much

more quickly than in equities. In

what ways does high frequency

LMAX Exchange order book data,

which provides insights into

prices and trading volumes at a

microsecond level, fill a key gap in

the pricing dynamics of currency

pairs immediately preceding and

succeeding events dates?

How would you summarise the

key benefits of your real-time and

historic FX data and how can clients

access it?

LMAX Exchange’s firm and executable

real-time FX data supports a variety

of applications, including algorithmic

trading, predictive market forecasting,

and improved execution quality. Our

historical FX data offers valuable

insights for refining strategies,

providing clients with access to

timestamped data, trade direction

(buy/sell), volume, and traded price

How have you leveraged state-ofthe-art

technology to deliver the

millisecond performance required?

Our order book data provides insights

into prices and trading volumes at

the microsecond level, playing a

crucial role in capturing the rapid

dating back to 2019. This combination

of real-time and historical data helps

clients make more informed trading

decisions and optimise their strategies.

We leverage our proprietary

technology and global infrastructure

to deliver the millisecond performance

required. With matching engines

located in key global trading hubs

– London (LD4), New York (NY4),

Tokyo (TY3), and Singapore (SG1)

price movements that occur around

key events in the currency markets.

By leveraging historical data, we’ve

run models that generate predictive

insights. For example, price declines

in EUR/USD greater than 2bps within

0.05 seconds are strong indicators of

Our data is accessible to all clients,

regardless of size, through multiple

connectivity options via FIX (4.2/4.4)

or REST APIs, and we also support

a range of additional connectivity

solutions to ensure seamless

– we ensure low-latency access for

Hawkish Fed outcomes. Trades placed

integration.

1.

https://www.clarusft.com/fx-clearing-2024-a-break-out-year-for-options/#:~:text=The%20cleared%20FX%20market%20experienced,%24125%20billion%20in%20FX%20futures.

MARCH 2025 e-FOREX 47


The FX Swaps market

in 2025 – All change

Stephan von Massenbach talks to e-Forex about the key themes for

2025 and how DIGITEC continues to innovate to stay at the forefront of

FX Swaps technology

PROVIDER VIEWPOINT

Stephan von Massenbach

What are the key industry themes

for 2025?

We recently returned from Tradetech

FX in Miami and there were three

recurring themes that dominated

panels and conversations in and

around the conference.

Firstly, workflow automation is not a

new theme for the FX market, but the

pace of change is increasing as firms

of all sizes try to automate every part

of their trading workflows. In the past

this was done to cut errors, increase

efficiency and add scalability, but now

it seems that workflow automation is

less about optimisation, but very much

needed for firms to stay competitive.

Secondly, managing market data is

vital. With sophisticated models and

pricing engines able to incorporate

many different types of financial data

from multiple sources, the value of

market data continues to grow. As

an example, in the FX Swaps market

trading firms are now using our D3

pricing service to build their curves

using data sources including FX Swaps

and Forwards, FX Spot, STIR Futures,

OIS, IRS and Cross-Currency Basis

Swaps. As new data sources from

different markets become available

the more technologically advanced

firms are subscribing to this data to

give them an information and speed

advantage in FX trading.

And thirdly, FX Swaps and NDFs

markets continue to evolve. Year after

year these markets are becoming

increasingly electronic, with new

liquidity pools launching and

overall market volumes growing.

The combination of more electronic

trading and more liquidity pools

means that accessing FX Swaps pricing

is more efficient, which makes them

even more attractive to trading firms

and new entrants. The bank-to-client

market is already highly electronic,

but we are starting to see a growing

interest in electronic trading in

interbank markets like 360T SUN and

LSEG FX Forwards Matching.

You launched D3 OMS at the end of

2023. What progress have you made

automating the interbank FX Swaps

market?

We developed D3 OMS to increase

end-to-end workflow automation and

enable traders managing FX Swaps

risk to connect directly to interdealer

FX Swaps venues and efficiently place

and manage orders. Our first clients

went live in 2024, and we now have

firms enabled across all time zones.

We expect more volume to migrate

to electronic channels this year, as

additional clients onboard and new

interdealer venues emerge.

You have just launched a new

service called D3 channels. Can you

tell us about it.

D3 channels is the latest addition

to our D3 suite of pricing tools,

which includes D3 sheets and D3

curves, for FX Swap and NDF curve

construction. We built D3 channels in

response to traders and eFX businesses

which wanted more control of the

trader price element of their client

pricing. D3 channels simplifies the

management of volume- and tierspecific

pricing adjustments that

are applied after the core price for a

currency pair has been built.

D3 channels allows traders to establish

easily maintainable, rule- and scenariobased

logic that automates pricing

decisions based on tier, volume band,

and destination. This ensures that the

system determines the exact price to

be sent in response to downstream

requests, alleviating pressure on

traders during potentially high-stress

market situations. By providing

greater control and visibility, D3

48 MARCH 2025 e-FOREX


PROVIDER VIEWPOINT

D3 Pricing Workflow

channels enables trading desks to

scale their operations, moving higher

volumes to electronic trading channels.

Importantly, D3 channels integrates

with any D3 setup and in-house

builds and connects to downstream

systems. It enables traders to focus

on executing active strategies rather

than responding to individual requests,

freeing up resources to expand into

additional currencies and manage

larger volumes effectively.

You previously mentioned that

regional banks and smaller market

participants have become an

important target group for D3. Is

that still the case?

Over the past year our client numbers

have increased by 15 per cent, partially

driven by regional bank adoption of

our services.

In the past, many banks managed

their FX Swaps books using Excel,

which required high levels of manual

intervention. However, now that FX

Swaps and NDFs are priced more

aggressively and many far-side clients

transact in multi-dealer environments,

regional banks are looking to

technology that can help them to

compete effectively for client business

with more accurate pricing, and faster

response times. It is now standard

market practice for far-side clients to

analyse quote quality, either directly

or via trading venues, meaning that

banks must have quote speed and

pricing accuracy to keep their share of

client business.

Additionally, DIGITEC’s products

and services are delivered as SaaS

solutions. This makes our suite of

D3 pricing services more accessible

and means that regional banks do

not need to invest in on-premise

technology. This makes implementation

and any subsequent upgrades

much more efficient. Many smaller

regional banks initially use our D3

Lite service, which is a plug-and-play

web-based application with some of

the features of D3 accessible via GUI.

They frequently see their FX Swaps

and NDF business grow in volume as

a result, and then upgrade to our full

D3 pricing service as their businesses

evolve.

Looking forward, how do you see

the FX Swaps market evolving over

the next year?

We expect the FX Swaps market to

continue to grow and evolve in 2025

and we are continuing to invest and

innovate in this area, as DIGITEC has

done for 45 years. We are fortunate

to have more than 50 per cent of the

largest FX banks as our clients and SaaS

deployment allows us to widen our

potential client base far beyond the top

100 banks, which enables many more

potential clients to participate in the FX

Swaps and NDF markets.

As a specialist provider of technology

solutions we are always aiming to

set new standards in the FX Swaps

market with our three core services

- D3 sheets for improved curve

construction, pricing accuracy and

the subsequent distribution to

downstream systems (including D3

curves and D3 channels), Swaps

Data Feed for greater transparency

and access to key market data, and

D3 OMS to support the automation

of interbank trading on electronic

platforms.

MARCH 2025 e-FOREX 49


THE E-FOREX INTERVIEW

Saxo Bank:

From online

broker to global

banking group

James Dewdney-Herbert

50 MARCH 2025 e-FOREX


THE e-FOREX INTERVIEW

Saxo Bank is a name synonymous with Fintech innovation. The company pioneered online FX

trading, connecting retail clients to platforms, products and liquidity previously only available to

institutions. We spoke to James Dewdney-Herbert, Director of e-FX sales at the firm to discover more

about how it has been growing its institutional business.

James please give us a brief history

of Saxo Bank.

Saxo was founded in 1992 by Lars

Seier Christensen, Kim Fournais, and

Marc Hauschildt in Copenhagen,

Denmark. Originally named Midas

Fondsmæglerselskab, the firm began as

a small brokerage company providing

clients with FX and CFDs. The founders

shared a common vision of leveraging

the internet with trading technology

to create a new type of brokerage, a

Fintech. They wanted to democratise

trading and investment and technology

made this possible.

In 2001 Midas underwent a significant

transformation, rebranding itself as

Saxo Bank. The new name reflected

the company’s aspirations to become

a leading player in the global financial

industry. Throughout the early 2000s,

Saxo expanded its products and

presence, opening offices in London,

Paris, Zurich, and Singapore. Since then

Saxo has grown into a Systemically

Important Financial Institution (SIFI) in

Denmark where it is Headquartered.

Today the bank serves 1.3million

customers directly and millions more

indirectly through its White Labels.

Prime of Prime called IS Prime. Here we

aimed to address the retail brokerage

industry’s liquidity requirements. In

both these roles I gained valuable

experience talking to both sides of

the trade but also being involved

in a broader business development

capacity. I then moved to the far east

to work for Finalto where I covered

Institutional Sales. These experiences

were valuable because I was exposed

to different parts of the business, in

different geographies, across liquidity,

product, origination sales, relationship

management, onboarding and client

services.

When I had the opportunity to

join Citibank’s FXPB in Singapore

I leapt at the chance to join a

blue-chip FX company. This was a

fascinating experience where I was

managing FX option life-cycle events,

novation’s, portfolio compressions

and relationships with the most

sophisticated FX traders. I came back

to the UK in 2020 and have been

fortunate to be with Saxo since.

What does your day-to-day job

typically involve?

We have a daily team meeting in

the morning where we go over the

numbers, our priorities and challenges.

For most of the day I am speaking to

potential new clients, existing clients

and liquidity providers. I am also

engaging internal teams - onboarding,

credit risk, or e-trading support. I

spend time looking at the client’s

flow, volumes and PnL decay curves,

and checking the performance of the

liquidity pools we operate.

What capital market solutions does

Saxo offer for institutional firms and

what mix and types of clients are

you providing these for?

Saxo operates a fully integrated

execution to custody business model

for funded securities. This covers global

equities and ETFs, investment trusts,

mutual funds and fixed income. We

offer several client omnibus solutions

for b2b2c business. At the more

You have been working in this

industry for a long time. How

has your own career pathway

developed so far?

I started in FX in 2010 working on the

FX Agency desk for Market Securities

Kyte Broking. Our desk covered e-FX

(Spot) and Options serving both buy/

sell side. Subsequently I joined a

Hedge Fund, ISAM, to establish an

e-FX Agency which evolved into a

Saxo is a pioneer with 30+ years of experience

MARCH 2025 e-FOREX 51


Saxo Bank: From online broker to global banking group

SAXO GROUP HEADQUARTERS,

DENMARK

THE E-FOREX INTERVIEW

involved end full White Labels allow

established institutions to leverage the

banks technology stack including front

end platforms and business processes

such as corporate actions. At entry

level a simple client omnibus with

APIs are available. The typical White

Label client would be an established

Institution which might not have

optimal Digital tools and therefore

makes the choice to ‘buy not build’.

These clients achieve massive scale

with minimal CAPEX/OPEX relative to

the opportunity they aim to address.

Our clients range from banks, brokers,

corporates to fund managers and family

offices. We also offer a full suite of

services for wealth management and of

course solutions for prop trading firms.

What do your institutional clients

value most about doing business

with Saxo?

Our coverage teams are operational when markets are open and follow the sun from Singapore over to

Europe and the UK

The clients tend to recognise the level

of service. Institutional clients have

several coverage points, an overall

‘relationship manager’ as well access

to the Prime Services Team (effectively

an institutional client services group)

additionally we have a Sales Trading

Desk and a E-Trading support group.

52 MARCH 2025 e-FOREX


THE e-FOREX INTERVIEW

The coverage teams are operational

when markets are open and follow

the sun from Singapore over to Europe

and the UK.

What range of instruments can

institutional clients now access with

Saxo?

operational synergy and access to

the markets top Liquidity Providers

and Venues. Professional, corporate

and institutional clients execute

and manage their foreign exchange

liquidity through a single, unified

platform. Clients access consolidated

liquidity, clearing, credit and

EMS technology together with

comprehensive pre- and post-trade

Clients are able to access 71,000+

instruments across margin and cash

products. For example, Cash Equities

and ETF’s, Mutual Funds, Fixed Income,

Foreign Exchange and Bullion Spot,

Forward and Options, Listed and OTC

Derivatives.

FX Prime Brokerage is an important

part of your Institutional offering.

Please tell us more about that.

Saxo’s FX Prime Brokerage helps

clients seeking capital efficiency,

Our clients range from banks, brokers, corporates to fund managers and family offices

MARCH 2025 e-FOREX 53


Saxo Bank: From online broker to global banking group

THE E-FOREX INTERVIEW

Saxo operates a fully integrated execution to custody business model for funded securities

service. OTC and Listed liquidity are

available across Spot, Forward/Futures

and Vanilla Options.

The main advantage is the optionality

to execute and manage flow via several

different EMS mediums: Platforms,

API’s, Smart Phone APPs and Voice.

Via these clients access a substantial

network of liquidity providers via

sophisticated technology with high

touch support.

How have you made integration and

connectivity to your services as easy

as possible?

Saxo’s FXPB service supports

interoperability with clients’ existing

infrastructure. Saxo offers a range of

APIs that enable clients to connect

their proprietary trading systems, order

management systems (OMS), and

risk management systems with the

platform. Inter-operability is enhanced

by the Open (Rest) API allowing clients

to absorb information packages into

native systems systematically. Colocation

opportunities are available

in Equinix LD4, NY4 and CP3

Copenhagen.

FXPB is a very competitive industry.

What sets you apart from other

firms?

What sets the business apart from

other prime of prime peers is twofold;

Saxo operates a dual FX agency/

principal liquidity model which

combines the markets best liquidity

together with the bank’s own unique

liquidity. This reduces transaction

costs for clients. Saxo FXPB offers all

the top Euromoney banks, electronic

communication networks (ECNs)

and listed venues. Client’s codesign

bespoke engagement’s and

fix sessions to facilitate disclosed,

semi-disclosed and anonymous

participation. This ensures choice to

suit their objectives, more akin to a

Tier1 FXPB.

Second Saxo offers multi-asset

execution and custody. Various

strategies across L/S Equity, Global

Macro, Volatility, Stat Arb, Event

Driven, Quantitative and Managed

Futures can be deployed solely with

Saxo. This brings profound operational

and treasury efficiencies. For example,

clients who hold securities get margin

relief towards derivatives and through

a single integration point enjoy

consolidated execution, reporting and

cash management.

What value added and other

services do you provide for your

clients?

Saxo provides high-touch,

personalised, support to clients.

Dedicated relationship managers

and support teams are available

24/6. The relationship manager

works closely with the client to

understand their specific needs and

objectives and provide personalized

support. Support teams are highly

54 MARCH 2025 e-FOREX


THE e-FOREX INTERVIEW

knowledgeable, ensuring prompt

and professional assistance.

Saxo pursues a fully transparent,

data driven approach to transaction

cost analysis (TCA) and provides

clients with detailed insights into

their trading activity, allowing them

to monitor liquidity provider/venue

performance and manage liquidity

more effectively. Saxo uses a leading

TCA platform FairXChange as well as

its own proprietary interpretations

of flow. This allows clients to better

understand their business and make

informed decisions.

Saxo’s Strat’s Team generates market

analysis, research and commentary

which it makes available (for free)

online/on-platform. The Global

Market Quick Take is produced daily

and explores the prominent themes

of the previous 24 hours. Saxo strats

are most famous for the ‘outrageous

predictions’ which look to the year

ahead and assesses outlier events

Saxo provides high-touch, personalised, support to clients

which can move markets. Clients

use this analysis in their own

research notes for their clients, Saxo

continually supports the b2b2c value

chain.

Saxo is of course an e-FX pioneer

with over 30 years of experience

and as already mentioned has

been designated as a Systemically

Important Financial Institution

(SIFI). What does that mean and

what additional responsibilities

does it bring with it?

The SIFI designation is a

categorisation of financial institutions

that play an important role in

ensuring the stability and proper

functioning of the financial system.

OUR AI ENGINE

ENABLES A FULLY

CUSTOMISED

ONBOARDING

EXPERIENCE

Saxo’s appointment as a SIFI

highlights the bank’s integral position

as it supports a growing number of

clients, as well as banks, brokers,

asset managers and other industry

participants who rely on its stability

for their assets and cash as well as its

platforms for market facilitation.

The additional responsibilities

include robust risk management,

higher capital requirements,

detailed resolution plans, rigorous

stress testing and strong corporate

governance. These are designed to

protect the broader economy caused

by any potential failings of a SIFI.

How important has your ongoing

investment in technology been

in helping you to stay ahead of

competitors and in what sort of

ways does it help you to provide

a state-of-the-art experience for

clients?

Saxo pursues a ‘Digital Platform First’

ethos, prioritising digital solutions and

platforms for the delivery of financial

services. The approach emphasises

leveraging technology to enhance user

experience, streamline operations,

and provide clients with efficient,

accessible and innovative financial

services. This prioritisation helps Saxo

MARCH 2025 e-FOREX 55


Saxo Bank: From online broker to global banking group

stay at the forefront of technological

advancements in the industry.

The bank continuously invests to

enhance the platform and improve

service. For example, it recently

released FX Options ‘Strategies’ Ticket,

allowing simultaneous trading on up

to 10 vanilla options from the same

ticket. All legs are executed in one go

however where strategies combine

buys and sells Vega netting applies,

and spreads are tightened versus

trading separate legs. It is also more

convenient and controlled than trading

the legs separately.

THE E-FOREX INTERVIEW

Transaction costs are further reduced

on the Delta Exchange which Saxo is

happy to facilitate at mid-spot. A risk

graph visualises the payoff profile at

expiry. The FX options product caters

to money managers covering Global

Macro and Volatility. But also offers

opportunities for risk managers that

might be more cost effective than

Spot/Forwards.

In what ways do you think the

FX market has been evolving that

plays into the strengths of a leading

institutional provider like Saxo?

The main forces that have shaped the

evolution of the FX market are on the

one hand regulation and on the other

technology. Our clients are dealing

with a regulated European Banking

Institution with a SIFI status and S&P

A- credit rating.

Saxo pursues a ‘Digital Platform First’ ethos, prioritising digital solutions and platforms for the delivery of financial services

We are committed to higher industry

standards and take pride in being at

the forefront of industry reforms. Our

commitment to transparency is proof

that our interests are fully aligned

with our clients’. For example Saxo

was one of the first institutions to sign

and act in accordance with the FX

Global Code: a commitment to stricter

customer protection and transparency

in the FX market.

56 MARCH 2025 e-FOREX


THE e-FOREX INTERVIEW

WE STRIVE TO PROMOTE

HIGHER STANDARDS IN THE

MARGIN TRADING INDUSTRY BY

EMBRACING NEW REGULATION

FOR CUSTOMER PROTECTION

AND RESPONSIBLE TRADING,

INCLUDING ESMA’S MEASURES.

WE ALSO FULLY DISCLOSE OUR

DEALING PRACTICES AND CLIENT

PERFORMANCE TO DEMONSTRATE

OUR COMMITMENT TO FAIR

OUTCOMES, EXECUTION QUALITY,

AND TRANSPARENCY WITHIN THE

FINANCIAL INDUSTRY.

FINALLY OUR CLIENTS BENEFIT

FROM QUALITY TECHNOLOGY,

BECAUSE IT UNDERPINS

EVERYTHING SAXO DOES. IT

WOULD BE DIFFICULT TO IMAGINE

A MULTI-ASSET PLATFORM THAT

IS BETTER THAN SAXO’S WHICH IS

WHY TIER 1 BANKS AND WEALTH

FIRMS HAVE WHITE LABELLED

IT. SAXO’S WHITE LABELLING

FRANCHISE IS A PROFOUND

SEAL OF APPROVAL FOR ITS

TECHNOLOGICAL PROWESS.

MARCH 2025 e-FOREX 57


AI in FX:

Hype or high-performance?

By Matthew Hodgson, CEO of Mosaic Smart Data

EXPERT OPINION

AI is following hot on the heels of

automation, playing a game-changing

role in foreign exchange trading. The

cleared FX market experienced strong

growth in 2024, reaching $18 trillion

in notional cleared, a 33% increase

compared to 2023. 1 And now AI is

poised to supercharge this growth

even further.

But as Celent stated in a recent

report: “The initial excitement

surrounding generative AI has given

way to a more focused approach, as

financial institutions now prioritize

practical applications and sustainable

growth strategies while continuing

to innovate with this transformative

technology.”

Rather than viewing innovation

as a ‘nice to have’ expense, firms

are increasingly looking to new

technologies like AI to drive the

58 MARCH 2025 e-FOREX


EXPERT OPINION

efficiency and cost-effectiveness of

their operations, with a laser focus on

ROI for any new solutions they deploy.

In the field of data science, AI can be

leveraged to derive insights that FX

participants can easily interpret and

use to detect market movements,

enhance trading models and build

informed strategies. This has emerged

as a real-world use case that is

leading the pack when it comes to the

practical deployment of AI in the FX

space, because it delivers clear ROI,

enhances productivity and profitability

and leads to strengthened client

relationships.

In order to quantify the value that

AI-driven data analytics can offer FX

trading firms, Mosaic Smart Data

conducted a survey among its global

user base. The results tell a powerful

story about how AI is delivering

tangible and measurable value to

Mosaic’s FX clients, transforming the

way they operate and perform.

Overall, the standout takeaway of the

survey was that Mosaic’s AI technology

directly drives business growth,

enhances visibility, and improves client

engagement. Results revealed:

• Improved Revenue and Growth:

A staggering 89% of users strongly

agree that Mosaic helps them

improve and grow their revenue,

showcasing how the platform

turns data insights into real

financial results.

• Client Acquisition and Business

Generation: 72% of users strongly

agree that Mosaic helps them

generate new business, proving its

ability to identify and capitalize on

opportunities.

• Quality Conversations and Client

Engagement: Regular, high-quality

client interactions matter, and

Mosaic delivers—78% of users

cite better-quality conversations,

while 67% see an increase in more

frequent client discussions.

• Customer Flow Visibility: 83%

of users strongly agree they gain

clear visibility into client flow,

empowering better decisions.

• Team and Performance

Management: 78% achieve

improved visibility of team

performance, enhancing

accountability and results.

• Reporting Made Seamless: 83%

of users agree Mosaic simplifies

reporting, ensuring management

has actionable, real-time insights

without the usual manual burden.

• Protecting the Base: 72% of

users believe Mosaic helps them

secure their existing business,

reducing churn and fortifying their

customer relationships.

• Catalyst for team synergy: 67%

agreed that the platform fosters

better colleague collaboration, it

bridges communication gaps and

aligns teams for success.

The survey provides valuable insight

into how AI can be an enabler of

growth, efficiency, and visibility. The

overwhelmingly positive response

- particularly in critical areas like

revenue growth, client visibility, and

reporting- demonstrates how Mosaic

delivers the right insights at the right

time to ensure sales teams are always

steps ahead of the competition.

Specifically, anecdotal evidence from

users reported three key benefits:

1. Growth of FX franchise: more

business secured from existing

clients

2. Protecting business: unwanted

client churn avoided

3. Ability to do more with less:

optimised use of team’s time

AI isn’t just another tool - it’s a gamechanger

for any FX business looking

to outperform and over-deliver.

1.

https://www.clarusft.com/fx-clearing-2024-a-break-out-year-for-options/#:~:text=The%20cleared%20FX%20market%20experienced,%24125%20billion%20in%20FX%20futures.

MARCH 2025 e-FOREX 59


Hybrid FX: leveraging the

strengths of both OTC and

listed markets

A growing number of OTC FX market participants are now using exchange-traded FX futures which

has led to a fast growing and vibrant hybrid market structure in which investors have a wider choice

of where and how to trade. We asked KC Lam, Global Head of Rates and FX, at Singapore Exchange,

to tell us more about this development and to outline the benefits it presents for both sell side and

buy side firms.

ASK A PROVIDER

At the same time, market participants

are increasingly using execution

algorithms to access as many liquidity

sources as possible across multiple

venues. They look at multiple data

sources, including the futures market,

and adjust their weightings to

account for the growth of futures.

As market participants become more

data-driven, the futures market is

becoming an important source of

price signals.

Banks can now connect seamlessly

to both the futures and OTC

markets. How important has that

development been in accelerating

the growth of FX futures trading?

While banks always had access to

exchange-traded instruments, their

adoption of FX futures has accelerated

due to the liquidity and capital

efficiencies these futures provide, and

their role in price formation and discovery.

KC Lam

Many OTC FX market participants

are now looking into ways they

can integrate FX futures into

their execution models. What’s

motivating them to do this?

In recent years, with more OTC

FX participants internalising flows

along with the growth of Multi

Dealer Platforms, coupled with the

substantial growth in volumes and

liquidity of FX futures, price discovery

for key FX currency pairs is beginning

to shift from primary OTC venues to

futures exchanges.

For example, market participants and

liquidity providers are incorporating

SGX FX Futures market data like

our USD/CNH and INR/USD futures

in their trading. This phenomenon

is not new as traders have also

been using CME’s G10 futures and

B3’s BRL futures as primary pricing

reference points and important

sources of liquidity. SGX USD/CNH

FX Futures, the world’s most widely

traded international renminbi futures,

saw a 66% year-on-year growth in

volumes for February 2025 to US$322

billion, with over 40% of our volumes

coming from U.S. and Europe time

zones.

As banks can access significant

liquidity in listed FX markets, it

enhances trading opportunities and

they can transfer their OTC risks

without information leakage, given the

anonymity of exchange-traded futures.

Arbitrage opportunities also arise from

the basis between OTC and listed FX.

What advantages do FX futures

trades offer for FX Prime Brokers

and in what ways are they playing

an increasingly pivotal role in

facilitating access to this market?

By collaborating with their futures

clearing counterparts, FX Prime Brokers

60 MARCH 2025 e-FOREX


ASK A PROVIDER

can offer more trading opportunities

through basis swap products. With

FX futures gaining in liquidity and

prominence, basis swap products can

not only increase trading volume but

also help FX Prime Brokers use their

capital more efficiently.

For popular FX pairs like USD/

CNH, where CNH is not eligible for

settlement through the Continuous

Linked Settlement (CLS) system, FX

Prime Brokers can leverage basis swap

products to transfer positions into

futures where they can be netted and

thereby optimise credit line usage.

Bilateral dealer-client relationships

are a well-established feature of

the OTC FX markets and one that

many buy-side firms do not want to

lose. What threats, if any, does the

futurisation of FX present to these

links?

The futurisation of FX enriches the

FX trading ecosystem by enabling

more trading opportunities and better

capital utilization, adding a positive

dimension to established dealer-client

relationships. The bilateral nature of

FX trading will remain, and we see

this complemented by the growing

connectivity between OTC and

exchange-traded FX, which offers

better information sharing and risk

management.

How do FX futures effectively

mitigate other OTC FX market

challenges?

FX futures offer a more efficient format

with a single day market period of risk

(MPOR) compared to the 5-day MPOR

for cleared OTC FX, aiding compliance

with regulations like Uncleared Margins

Rule (UMR) and Basel III Standardised

Approach for Measuring Counterparty

Credit Risk (SA-CCR). Derivatives

exposure for FX futures positions can

be significantly lower when compared

to a portfolio of OTC uncleared

derivatives, especially when multiple

counterparties are involved.

Additionally, clearing FX futures

through a central counterparty

(CCP) reduces counterparty risk and

regulatory costs. The liquidity and

transparency of FX futures offers

better price discovery and tighter bid/

ask spreads, leading to more efficient

trading. The standardised nature of

FX futures also simplifies operations

and reduces administrative burdens

associated with managing bespoke

OTC FX instruments. Overall, FX

futures provide broader market access,

allowing participants to trade in a

regulated environment with robust

risk management frameworks, which

is particularly beneficial for smaller

firms or those looking to diversify their

trading strategies.

In what ways does combining OTC

and listed markets allow FX traders

to manage risk more effectively?

Connecting to highly liquid listed FX

markets enhances hedging and trading

opportunities, compared to trading

on OTC FX venues alone. For listed FX

futures which are less liquid, traders

can use basis swap products to price

trades in the more liquid OTC market

and settle in the futures market. This

combination solves the longstanding

issue of capital inefficiency and delivers

benefits such as more accurate pricing

and better risk management.

How much of a challenge is

integrating FX futures into OTC

workflows and what’s been done to

make this as easy as possible?

Integrating FX futures into OTC

workflows varies depending on the

end user. The workflow for an asset

manager will differ from that of a

hedge fund or a bank. Hence, there

is opportunity for bespoke solutions

in workflow, risk management and

integration.

Advancements in electronic trading

platforms have streamlined this

integration process, making it easier to

manage both OTC and futures trades

on a single platform. Moreover, the

standardised format of listed FX helps

to replicate OTC positions efficiently,

reducing the need for extensive

adjustments.

Despite the success of the hybrid

trading model, what work still needs

to be done to promote the benefits

of trading FX futures and to develop

the kind of tools and technology that

will ensure it becomes a long-term

fixture of the market?

A successful hybrid trading model is

achievable when both OTC and listed

FX futures are fully normalised for

trading and risk management. This

requires continuous innovation and

development of systems and tools that

work seamlessly in this new trading

environment. The ongoing convergence

of OTC FX and FX futures will transform

how market participants manage risks

and capital efficiently.

In what ways do you think the

transition to a hybrid structure will

ultimately shape the future of global

FX markets?

A hybrid structure will drive higher

growth in the FX markets. Participants

will benefit from improved risk

management, lower regulatory

compliance costs and better capital

use. It will also spur innovation to

meet the demand for sophisticated

trading platforms. Additionally, it will

democratise access, enabling smaller

firms and new entrants to participate

easily. Increased competition and

innovation will ultimately create more

dynamic, efficient, and resilient global

FX markets.

MARCH 2025 e-FOREX 61


5 key takeaways from

TradeTech FX USA 2025

Pictures by Richard Hadley

360T was once again a sponsor and active participant in the TradeTech FX (TTFX) USA

conference in Miami, which brought together over 500 senior FX industry professionals for three

days of discussions, analysis, and debates on key marketplace issues. Given the extensive industry

representation at the conference and the breadth and quality of the sessions, we thought it would

be useful to provide a roundup of our key takeaways from the event.

RECENT EVENT

1. 360T’S NEW PARTNERSHIP

GENERATES SOME BUZZ

There was considerable buzz at this

year’s TradeTech FX USA conference

following the announcement on the

opening day of a new partnership

between 360T and Quantitative

Brokers (QB), which had already

garnered media attention. QB,

an independent specialist algo

provider, has been highly successful

in the Futures, US Cash Treasury,

and Options markets and has now

launched a suite of FX-optimised

Algos. Under this partnership, these

Algos are now available via 360T.

Interest in the announcement was

heightened by the strong presence of

both companies at the conference.

David Kalita, CEO of QB, and Matt

O’Hara, CEO of 360T Americas,

participated in panel discussions.

O’Hara also delivered a keynote

speech during the buy-side-only

“Innovation Day” and hosted

a lunchtime masterclass on the

evolution of the 360T Execution

Management Systems (EMS). And,

naturally, representatives from both

companies discussed the partnership

with friends and partners across

both the buy-side and sell-side in a

more informal environment at the

networking event hosted by 360T,

UBS, Wells Fargo, Deutsche Bank,

HSBC and BNP Paribas after the first

day of the main conference.

In his keynote address, O’Hara noted

that 78% of the buy-side audience

members polled at TTFX USA the year

before had expressed an interest in

having access to third-party Algos

to complement their current bankprovided

options, and this interest

was evident in the comments and

questions from the attendees this year

about the partnership. Put simply,

attendees showed an appetite to

maximise and diversify their execution

tools and strategies, with a goal to

optimise trading, minimise market

impact and reduce overall costs

2. A CHANGING LIQUIDITY

PARADIGM

Every TradeTech FX event inevitably

features a panel focused on the state

of liquidity in the marketplace, and

this panel is always well attended. This

year was no exception, and it was

perhaps one of the livelier discussions

at the event. Although the speakers

on this panel expressed concern

about the declining influence of the

“primary” FX venues, they agreed

that the FX Global Code of Conduct

has helped to improve market

conditions by reducing liquidity

recycling and increasing

transparency around hold times.

During the conversation it was also

claimed that adoption of the Code

has primarily been driven by the sellside

and technology providers, but

now the responsibility for sustaining

these market improvements is shifting

towards the buy-side. A key takeaway

from the discussion was the state of

risk capital in FX. Panelists observed a

decline in available risk capital, largely

due to regulatory changes that have

made FX a more capital-intensive

asset class, as well as the departure of

some banks from the market over the

long term.

It was pointed out that liquidity has

not seemed to significantly suffer

in daily trading because the speed

at which capital moves through the

system has compensated for the

lower volume of available capital

risk. One speaker claimed that this

creates an impression of liquidity

that is sometimes deceptive, pointing

out that when the speed of capital

movement slows, especially in one-

62 MARCH 2025 e-FOREX


RECENT EVENT

directional markets, the market’s

fragility becomes clearer.

3. DBG TURNOUT REFLECTS THE

EVOLUTION OF THE INDUSTRY

Deutsche Boerse Group (DBG) was

very well represented at this year’s

event with 360T, Eurex, QB and

Deutsche Boerse Market Data +

Services, all having a strong presence

at the conference.

Consider that 360T partners with

Eurex to provide access to Listed

and Cleared FX products, with QB

to provide specialist, independent

FX Algos and DBG MD+S as an

additional distribution channel for our

award-winning suite of Market Data

products.

Consider also that 360T has

partnerships in place with two

other DBG firms, CryptoFinance for

cryptocurrencies and SimCorp as an

OrderManagement System (OMS).

Then there is the lesser-known fact

that 360T and many of its major

competitors work together, a fact that

was addressed in the panel O’Hara

participated in. Although the speakers

were all technology providers and, to

varying degrees, competitors, they all

acknowledged that there are specific

areas where they all cooperate to

better service their clients. With

growing expectations of what FX

technology providers should offer, no

single provider can realistically meet

all these demands while still offering

the highest levels of performance.

Furthermore, economic pressures on

both buy-side and sell-side firms are

MARCH 2025 e-FOREX 63


5 key takeaways from TradeTech FX USA 2025

driving a preference for accessing

multiple trading tools and services

through a single connection. All this

means that technology partnerships

are likely to only proliferate and

increase in prominence

RECENT EVENT

4. CORPORATE TREASURERS

GET IN ON THE ACTION

This year, there was a noticeable

increase in the conference agenda

dedicated to the FX concerns of

Corporate Treasurers, alongside a

corresponding rise in attendance

from this segment. Obviously, the

focus for Treasurers when it comes

to FX is very different compared

to the Hedge Funds and Asset

Managers who comprised most of

the buy-side attendees at TTFX USA.

Treasurers approach FX differently

because FX is typically only a small

part of their role, with execution

being just one component of

broader FX management strategies

centered around topics like exposure

forecasting and hedging. Additionally,

they assess bank pricing in the

broader context of their overall

banking relationships

However, some of the more

technologically savvy Treasurers are

beginning to explore how tools

and functionalities developed for

other client segments can enhance

their FX trading. This trend was

evident during 360T’s lunchtime

masterclass, which outlined the

key capabilities of 1st, 2nd, and

3rd generation EMS platforms and

discussed future innovation. Among

the attendees were Treasurers from

major international corporations,

some of whom were among the

30+ institutional buy-side firms that

participated. One Treasurer shared

that they had recently executed the

first Mixed Givens trade via the 360T

EMS, a new workflow tool which

enables users to net trades within a

single currency pair that have different

64 MARCH 2025 e-FOREX


MARCH 2025 e-FOREX 65


5 key takeaways from TradeTech FX USA 2025

RECENT EVENT

notional currencies while also receiving

streaming pricing in competition.

Both Corporate Treasurers and Asset

Managers at the masterclass agreed

that this functionality could drive

cost savings, streamline operations,

and support best execution – a

clear example of overlapping needs

between all three client segments.

5. FX IS…COOL?

During the opening address of

TTFX USA, the conference chair

referenced a Bloomberg article

which had been published that very

morning. It claimed in its headline

that FX was, once again, “cool”.

The article suggested that, aside

from brief periods of sharp but

short-lived volatility, FX markets had

been relatively placid for some time.

However, shifting geopolitical and

macroeconomic factors are now

driving increased market activity.

The implications for the broader

world remain uncertain, but for the

FX market, the result appears to

be greater volatility, which tends

to sharpen the focus of industry

participants.

For Liquidity Providers who can

effectively navigate this volatility, as

well as for alpha-seeking Hedge Funds

and Asset Managers, this presents new

opportunities. However, for market

participants focused on hedging

and risk mitigation, it necessitates a

reassessment of risk management and

trade execution strategies.

For technology providers like 360T,

this shift underscores the need for a

highly consultative approach, working

closely with all segments of the FX

industry to understand evolving

needs and align technological

innovation accordingly.

Is any of this, actually, cool? Maybe

not—but the heightened excitement,

engagement, and urgency at this

year’s TTFX USA conference suggest

that FX is certainly more dynamic

than it has been in recent years.

66 MARCH 2025 e-FOREX


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68 MARCH 2025 e-FOREX

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