The explicit link here between the FX Global Code and the Senior Managers Regime (SM&CR) is a sign of things to come. 

The regime was introduced, originally for banking only, as part of the political and regulatory response to the financial crisis. It has since been extended to insurance, and the FCA is about to consult on rolling it out to the remaining c.50,000 regulated firms.

Unlike the approved persons regime it replaces, SM&CR covers all aspects of firms' business, which makes it an inescapable for regulators to use as a hook for any new regulation, or in this case code. The consequences are likely to be profound, with some surprises along the way.