FX Global Code
XMG FX Trading Disclosure
Version 1.0 · Effective date: October 27, 2026
1. About this disclosure
This disclosure explains how XMG, Inc. (“XMG”) acts when providing liquidity and trading foreign exchange with clients in the wholesale FX market. It supports XMG’s commitment to the FX Global Code and is referenced by XMG’s Liquidity Provider Disclosure Cover Sheet.
It applies to spot FX and non-deliverable forwards (NDFs) traded with XMG through any channel, including electronic venues, direct streams and requests for quote (RFQ). XMG Ltd does not yet trade FX with clients; this disclosure will be updated when it does. It does not replace the terms agreed between XMG and its clients; if they conflict, those terms prevail. XMG may update this disclosure and will publish the current version on its website.
2. Capacity
XMG acts as principal in all FX transactions with clients. When you trade with XMG, XMG is your counterparty and trades for its own account. XMG does not act as your agent, fiduciary or adviser, and does not owe you the duties an agent would.
Because XMG acts as principal, it may manage the risk from your trades by holding it, offsetting it against other trades, or hedging in the market. The prices XMG quotes reflect its own interests as well as market conditions.
3. Client data
XMG does not share information about your trading with third parties, other than the parties the Code exempts: regulators and authorities, settlement and clearing providers, prime brokers and other service providers acting for XMG, and others where required by law. XMG does not share client data in real time and does not provide it as a paid service. Because no other sharing takes place, there is no opt-out to offer.
4. Pre-hedging
XMG does not pre-hedge streamed or RFQ prices.
For large or risk transfer orders, assessed case by case, XMG may pre-hedge: that is, it may manage the anticipated risk of an order before accepting it. XMG does so only to manage the risk of the anticipated trade, never to profit at the client’s expense, and seeks to avoid moving the market against the client. XMG treats information from the client’s request as confidential throughout.
If you prefer that XMG does not pre-hedge an order, flag the order when you place it and XMG will not pre-hedge it. XMG does not notify clients separately before pre-hedging a specific order; this disclosure sets out when it may do so. Decisions to pre-hedge are made by XMG’s senior risk management and are recorded.
5. Last look
XMG applies last look to trade requests on its streamed prices. Last look is a short window in which XMG checks a trade request before accepting or rejecting it.
During last look, XMG runs two checks:
- Validity check: confirms the request is properly formed and within credit and other limits.
- Price check: compares the requested price with XMG’s current price.
The price check is symmetric. XMG applies the same tolerance whether the market has moved in XMG’s favour or the client’s.
The last look window is normally between 15 and 30 milliseconds. It covers the validity and price checks only; XMG adds no extra hold time.
XMG does not trade on information from a trade request during the last look window, and does not use it to inform pricing or trading if the request is rejected. XMG records a reason for every rejected trade request. On request, XMG will tell a client why a trade was rejected, and it provides clients with periodic reports on their rejection rates and last look hold times.
6. Order handling
Aggregation. XMG acts as principal and does not aggregate client orders.
Discretion. As principal, XMG decides whether, and at what price, to trade. Prices may vary with a client’s trading characteristics and with market conditions (see section 8).
Time-stamping. XMG time-stamps orders and trades on receipt, acceptance and execution to microsecond precision, and keeps these records.
7. Order types and fills
Market orders are filled at the next available XMG price.
Stop-loss orders. XMG accepts stop-loss orders. A sell stop triggers when XMG’s bid reaches the stop level, and a buy stop when XMG’s offer reaches it. Once triggered, the order becomes a market order and is filled at the next available XMG price, typically at a tighter spread. In fast or illiquid markets the fill price may differ from the stop level, sometimes significantly.
Partial fills. Orders may be partially filled, depending on the order type and the liquidity available to XMG at the time.
8. Pricing
Mark-up. XMG’s prices include a spread or mark-up. It varies by client, trading profile, size, currency pair and market conditions, and may widen around major market events and at times of low liquidity. Two clients may receive different prices for the same trade at the same time.
Fixing and benchmark orders. XMG may accept orders linked to a fixing or benchmark case by case. Before accepting, XMG agrees with the client the pricing basis, including any mark-up, and how the order will be handled.
9. Liquidity sources
XMG uses aggregation technology to source liquidity. It hedges on electronic venues including LSEG (Refinitiv FX Matching and FXall), EBS, Cboe FX (Hotspot), Currenex, LMAX, Euronext FX (FastMatch) and Integral. XMG may change the venues it uses without notice.
10. Confidential information and market colour
XMG treats client information, including orders, trade requests, executions and positions, as confidential. Access is limited to staff with a need to know, such as risk, compliance and operations, and is controlled through system permissions and information barriers. Client information is not shared with trading staff or teams outside client pricing.
XMG may share market colour. Any colour XMG shares is anonymised and aggregated and never identifies a client or its orders.
11. Contact
Questions about this disclosure: info@thexmg.com. This disclosure is maintained by XMG’s Chief Compliance Officer.