On 6 October 2020, the Financial Markets Law Committee (FMLC) published its response to the European Commission’s proposed Regulation amending the Benchmarks Regulation as regards the exemption of certain third-country foreign exchange (FX) benchmarks and the designation of replacement benchmarks for certain benchmarks in cessation. The FMLC draws attention to certain issues of uncertainty in relation to the proposed Regulation covering: potential discrepancies with action taken in other jurisdictions and proposed exemption for spot FX rates in restricted currencies.