If you only skim one market recap this quarter, make it this: FX volumes are up sharply, regulators are louder (and busier), and “reaction time” is becoming the real competitive edge.
1) Turnover is booming again (and not just in London)
Global OTC FX turnover hit $9.6 trillion per day in April 2025, up 28% from 2022, according to the BIS Triennial Survey (Банк международных расчетов). That’s the world’s cleanest pulse check for our industry.
The UK remains the single largest hub with $4.75T/day and ~37.8% global share. London didn’t just keep its crown; it widened the gap on depth and liquidity (Банк Англии).
Hong Kong accelerated fast: +27% to $883B/day. Swaps dominate there (about 64% of turnover), but spot and options also jumped (Hong Kong Monetary Authority).
So what? More flow sounds great—until you remember that more flow also means more micro-events to manage (rollover windows, liquidity pockets, queueing, hedging friction). That’s where operational risk—not market direction—tends to leak P&L.
2) Supervisors are not blinking
Across jurisdictions, the message is the same: protect retail investors, cut gaming, and harden operations.
ESMA’s 2025 updates highlight continued sanctions and measures across Member States—970+ actions and €100M+ in fines tied to 2024 activity, underscoring that enforcement is not a headline—it’s a habit (Esma).
ASIC reported 7,561 misconduct reports in H1-2025 (with 5,909 tied to financial services and retail investor issues). Expect more scrutiny on CFD distribution, marketing, and fairness controls (ASIC).
ESMA’s TRV and newsletters keep stressing consumer protection and operational resilience as core risk themes going into 2026 (Esma).
So what? It’s not only about leverage caps or risk warnings anymore. Supervisors want to see explainable controls: when a rule fires, what changed, and why. Auditability isn’t a checkbox; it’s the new UX for compliance teams.
3) What readers actually react to (and why)
From scanning top industry pieces this year, three consistently high-engagement angles stand out:
- Fresh numbers with context — BIS turnover splits, center-by-center growth, and how that changes liquidity conditions hour by hour. Why it works: numbers age quickly; readers reward timely data (Банк международных расчетов).
- Reg enforcement with practical takeaways — brief roundups that turn actions/fines into checklists for product, risk, and marketing teams. Why it works: teams need “do this now” bridges between a headline and their roadmap (Esma).
- Operational micro-edges — posts about how tiny timing gaps or policy “gray zones” quietly cost brokers money (e.g., hedge latency, swap-free windows, session effects). Why it works: it’s relatable and fixes are concrete.
4) The 2025–26 setup in one screen: volume ↑, tolerance ↓
Here’s the paradox most broker CEOs mention privately: flow is growing, but the “supervisory patience window” is shrinking. ESMA’s regular TRV cadence and ASIC’s semiannual enforcement reports mean gaps get noticed—and memorialized—faster than before (Esma).
Concretely, expect pressure on:
- Marketing and onboarding (claims, targeting, inducements): old ESMA intervention logic still frames the debate; modern versions focus on outcomes and disclosure clarity (Esma).
- Operational resilience: timestamp integrity, reconciliation speed, and the time-to-hedge window are moving from engineering topics to board topics (Esma).
- Product governance: evidence that leverage, swap-free, and promo flags are bound to live states (KYC segment, inactivity, exposure) rather than set-and-forget. This is where many lapses originate, per enforcement narratives (ASIC).
5) Trendlines to watch (and how to act now)
a) Liquidity shifts around the clock
With turnover higher and centers like HK pushing up swaps and spot, micro-structure around rollover and session overlaps matters more. Build rules that treat time as a risk vector — e.g., detection and guardrails for pre/post-rollover patterns (Hong Kong Monetary Authority).
b) From anomalies to similarity
Classic alerts catch outliers. 2025’s harder problem is coordinated normality — behavior that looks fine per account but correlates across many. Consider thresholds for behavioral similarity (timing, rotation, cooldowns) rather than only P&L spikes.
c) Audit trails as product
Regulators are publishing more and more consolidated outcomes. Make your risk rules explainable by default: what triggered, what changed, who approved, when it rolls back. It’s cheaper than a remediation program (Esma).
6) The outlook: competition on reaction time
If 2022–2023 was about surviving volatility and 2024 was about marketing cleanup, then 2025–2026 is about operational reaction time: how quickly your stack detects small structural edges and neutralizes them without punishing good flow.
That’s not a wall-of-metrics problem; it’s a rules-and-reflexes problem. Firms that encode policy into measurable, reversible actions will sidestep most of the drama and keep the upside of rising volumes.
Sources (short list)
- BIS Triennial Survey (2025): Global OTC FX turnover $9.6T/day, +28% vs 2022 (Банк международных расчетов).
- Bank of England on UK share: UK $4.75T/day, ~37.8% global share (Банк Англии).
- HKMA on Hong Kong: $883B/day, swaps ~64% of turnover (Hong Kong Monetary Authority).
- ESMA enforcement & TRV cadence: 970+ actions, €100M+ fines tied to 2024; ongoing TRV/newsletters in 2025 (Esma).
- ASIC (H1-2025): 7,561 misconduct reports; 5,909 in retail/financial services category (ASIC).
