Insights from Global FX Trading Quorum, London (remote participation ex-London), 2 December 2025

Download full Insights here.

Summary 

On 2 December 2025, at a meeting in London, buy and sell-side market participants - with special guest Andrew Pullman of PeopleClear - examined proposed reforms to the UK’s SMCR, with particular focus on non-financial misconduct and proportionality.

• Regulators are signalling greater emphasis on competitiveness and efficiency, but firms remain concerned about administrative burden and inconsistency.
• Defining integrity and acceptable behaviour remains a grey area, shaped by the growing overlap between regulation and employment law.
• Accountability increasingly depends on evidence of awareness and action, rather than outcomes alone.

Conclusion

The session concluded with recognition that SMCR remains a powerful but imperfect tool. Its success in improving culture continues to depend on clearer regulatory signals, proportional implementation and a more realistic balance between compliance effort and behavioural (and cultural) outcomes.

The session closed with a reminder that Quorum 15 is uniquely positioned to bring industry and regulators together under neutral conditions - not to lobby, but to create shared understanding across Europe’s fragmented equity landscape.