CLS Group
CLS Group, formally known for Continuous Linked Settlement, is a specialized financial market infrastructure company owned by major global financial institutions that provides settlement, processing, and data solutions to the foreign exchange (FX) market, with a primary mission to minimize systemic risk while enhancing funding and operational efficiency.[1] Established in 2002 by the global FX community in response to settlement risk concerns highlighted by events like the 1998 Russian financial crisis, CLS Group operates as an industry-owned consortium regulated by the Federal Reserve Bank of New York and other central banks.[1] Its core service, CLSSettlement, facilitates payment-versus-payment (PvP) transactions to eliminate Herstatt risk—the danger of one party defaulting after the other has fulfilled its obligation—across 18 major currencies.[2] Owned by over 75 of the world's leading financial institutions, including banks like ABN AMRO, Absa, and Australia and New Zealand Banking Group, CLS Group serves more than 38,000 users worldwide, processing instructions from thousands of counterparties daily.[1][3] Since its launch with 39 settlement members and seven currencies, the group has expanded significantly, now handling an average of over USD 7 trillion in daily settlement value, which represents a substantial portion of global FX turnover.[1][2] This multilateral netting process reduces funding requirements by over 96%, optimizes liquidity, and standardizes post-trade operations, thereby lowering costs and improving market resilience.[2] Beyond settlement, CLS Group offers advanced data solutions through CLSMarketData, drawing from over 3 billion FX trades since 2011 to provide market intelligence, aggregation, and reporting services that support regulatory compliance and trading strategies.[4] The organization continues to innovate, such as with the introduction of CLSClearedFX in 2018 for cleared FX derivatives, its redesign in 2025 with LCH ForexClear as the first central counterparty, and ongoing explorations into same-day settlement cycles to meet evolving market demands.[5][6] By fostering safer and more efficient FX trading, CLS Group plays a pivotal role in maintaining the stability of the world's largest financial market, which sees average daily turnover of USD 9.6 trillion (April 2025).[7]History
Background and Origins
The failure of Bankhaus Herstatt on June 26, 1974, exemplified the principal risk inherent in foreign exchange (FX) settlements, now known as Herstatt risk.[8] At 15:30 CET, German authorities closed the medium-sized bank, which was heavily involved in FX trading, just as its New York correspondents had released over $200 million in USD payments for DM it had received earlier that day.[8] Due to the six-hour time zone difference, the USD transfers occurred before Herstatt could deliver the corresponding DM, leaving counterparties exposed to the full principal amount without recourse, as the bank entered insolvency proceedings.[9] This event revealed how asynchronous settlement across time zones could amplify credit exposures in the growing FX market, where daily turnover had reached $185 billion by 1977.[8] The 1998 collapse of Long-Term Capital Management (LTCM) further illuminated systemic vulnerabilities in FX settlements amid broader market turmoil.[10] LTCM, a highly leveraged hedge fund with over $1 trillion in derivative positions including significant FX exposures, suffered massive losses following the Russian debt default in August 1998, leading to a near-failure that threatened global liquidity.[11] The crisis exacerbated FX settlement risks by straining counterparty credit lines and highlighting how interconnected FX trades could propagate failures across borders, reinforcing the unresolved dangers from events like Herstatt.[10] By September 1998, LTCM's distress had widened bid-ask spreads in FX markets and prompted central bank interventions to avert a broader meltdown.[12] In response to these persistent threats, the G10 central banks initiated coordinated discussions on mitigating FX settlement risk in the late 1990s.[13] Building on earlier analyses, the Committee on Payment and Settlement Systems (CPSS)—comprising G10 central banks—launched a 1996 strategy emphasizing private-sector solutions to eliminate principal risk, with targets for banks to reduce gross exposures and adopt safer practices by 2002.[13] This effort was spurred by FX market growth to $1.5 trillion daily turnover by 1998 and recurring crises underscoring the potential for a single failure to cascade globally.[14] The Bank for International Settlements (BIS) played a pivotal role in conceptualizing payment-versus-payment (PvP) mechanisms during the 1990s to address these issues.[15] In reports such as the 1990 Lamfalussy Report on netting schemes and subsequent 1994 guidelines, the BIS advocated PvP as a core principle, where final transfer of one currency occurs only if the counterpart currency transfer succeeds simultaneously, thereby discharging both obligations atomically.[16] These early PvP concepts aimed to neutralize time zone and operational mismatches in FX settlements, influencing global standards and paving the way for infrastructure like CLS Group as a direct response to such risks.[13]Formation
CLS Group was formed as a private-sector initiative to address settlement risks in the foreign exchange market, particularly those exemplified by the 1974 Herstatt Bank collapse. In July 1997, CLS Services Ltd was incorporated in London by a group of senior bankers from large international financial institutions active in the FX market.[17] This entity was backed by the G10 central banks, including the Federal Reserve and the Bank of Canada, along with major FX-dealing banks that provided initial funding and governance.[18] The initiative merged earlier efforts like ECHO and Multinet to create a unified facility aimed at reducing systemic risks through innovative settlement mechanisms.[18] In 1999, CLS Bank International was established in New York as a special-purpose Edge Act corporation under Section 25A of the Federal Reserve Act, receiving a banking license from the US Federal Reserve Board of Governors.[17] This structure was selected to leverage the US regulatory framework, which provided robust oversight for international banking activities, positioning New York as the operational hub for the settlement bank.[19] CLS Bank was designed as a limited-purpose institution regulated and supervised by the Federal Reserve, enabling it to hold accounts in multiple currencies and facilitate cross-border settlements.[18] The CLS System architecture was developed during this period, incorporating multilateral netting to compress gross obligations into net positions and payment-versus-payment (PvP) protocols to ensure simultaneous settlement of both legs of FX trades, thereby eliminating principal risk.[17] These features were rigorously tested in pilot phases from 1999 to 2001, involving initial settlement members and third-party banks to validate the telecommunications infrastructure, matching processes, and integration with central bank real-time gross settlement systems.[5] The pilots confirmed the system's ability to handle multilateral netting across multiple currencies while maintaining compliance with international standards for risk mitigation.[18]Launch and Subsequent Developments
CLSSettlement, the core service of CLS Group, officially launched on September 9, 2002, initiating operations with seven major currencies—the Australian dollar (AUD), Canadian dollar (CAD), euro (EUR), British pound (GBP), Japanese yen (JPY), Swiss franc (CHF), and US dollar (USD)—and 39 settlement members, achieving an average daily settlement value of approximately USD 300 billion.[5][20] This launch addressed the primary goal of mitigating foreign exchange settlement risk through payment-versus-payment mechanisms, building on the collaborative efforts established in prior years.[1] Subsequent expansions broadened CLSSettlement's scope significantly. In September 2003, four additional currencies joined: the Danish krone (DKK), Norwegian krone (NOK), Singapore dollar (SGD), and Swedish krona (SEK).[21] Further additions included the Hungarian forint (HUF) in November 2015, expanding the roster to 18 currencies by 2018, which has remained the current set.[22][23] Membership grew steadily, surpassing 60 settlement members by 2011.[24] In July 2012, CLS Bank was designated a systemically important financial market utility by the US Financial Stability Oversight Council, underscoring its critical role in global financial stability.[25] Recent developments reflect continued expansion and recognition. The 2024 interim financial report reported an average daily settlement value exceeding USD 7 trillion for CLSSettlement.[26] In 2025, U.S. Bank National Association joined as a settlement member on September 16, marking the third addition that year and bringing the total to 76 members.[27] CLSNet, the bilateral netting service, experienced 10% year-over-year growth in average daily netted value during the third quarter of 2025, reaching USD 176 billion.[28] Additionally, CLS was awarded "The World's Best Post-Trade Service Provider" at Euromoney's Capital Markets Awards 2025, highlighting its innovations in FX post-trade infrastructure.[29]Organization and Governance
Legal Structure
CLS Group Holdings AG serves as the parent company of the CLS Group, incorporated as an Aktiengesellschaft under Swiss law with its registered office in Lucerne, Switzerland.[30] It functions as a bank holding company and is regulated by the U.S. Federal Reserve as if it were a U.S. bank holding company, despite its Swiss incorporation.[17] The entity is ultimately owned by 79 shareholders, primarily consisting of CLS Bank International settlement members and their affiliates.[30] At the core of the group's operations is CLS Bank International, an Edge Act corporation established under Section 25A of the U.S. Federal Reserve Act, headquartered in New York City with additional facilities in New Jersey.[19] This U.S.-based entity is wholly owned by CLS UK Intermediate Holdings Ltd. and is responsible for handling foreign exchange settlements through its CLSSettlement service.[30] It maintains accounts in 18 eligible currencies and operates under supervision by the Federal Reserve.[19] The group includes several key subsidiaries that support its global activities. CLS UK Intermediate Holdings Ltd. is incorporated under the laws of England and Wales, with its principal office in London, and serves as an intermediate holding company for other entities.[19] Its subsidiaries encompass CLS Services Ltd. and CLS Processing Solutions Ltd., both incorporated in England and Wales and based in London, which provide operational support and non-settlement products such as data and reporting services, respectively.[30] Additionally, CLS US Services Inc. is incorporated in Delaware, with operations in New York, offering operational support to the settlement system and group entities.[19] Inter-affiliate service arrangements facilitate the group's efficiency, with subsidiaries providing corporate, operational, and processing services to one another and to CLS Bank International, while intra-group transactions are eliminated upon consolidation in financial reporting.[30] The CLS Group maintains global offices in London (United Kingdom), New York and New Jersey (United States), Tokyo (Japan, via representative office), and Hong Kong (via branch office) to support its international operations.[19]Ownership and Shareholders
CLS Group operates as a not-for-profit consortium owned by major global financial institutions that participate significantly in the foreign exchange (FX) market.[30] As of December 2024, it has 79 shareholders, primarily banks and financial entities such as Bank of America, Citigroup, and JPMorgan Chase, with no single shareholder holding more than 4.8% of the total share capital.[30][31] Shareholders must generally be settlement members or affiliates of CLS Bank International, ensuring they are active FX market participants; this criterion grants them benefits including access to CLS services like settlement and netting, as well as voting rights in governance decisions on a one-shareholder, one-vote basis.[30] Shares are not publicly traded and are held primarily for operational participation and risk mitigation in the FX ecosystem, rather than for profit distribution.[32] The ownership structure evolved from its inception, beginning with 17 founding shareholders—major banks—in 1997 to address FX settlement risks following global financial crises.[5] By 2017, the number had grown to 80, reflecting broader industry involvement, before a slight adjustment to 79 by the end of 2024.[33][30]Leadership
The leadership of CLS Group is headed by Chief Executive Officer Marc Bayle de Jessé, who was appointed in December 2019 and is responsible for overseeing the organization's overall strategy, operations, and risk management in the foreign exchange (FX) market infrastructure.[34] With over three decades of experience in market infrastructure, including roles at the European Central Bank as Director General for Market Infrastructure and Payments, Bayle de Jessé brings deep expertise in FX settlement and systemic risk mitigation to guide CLS's global activities.[35] The Board of Directors comprises 21 members, including 13 representatives from CLS's shareholder banks and 8 independent outside directors, ensuring a balance of industry perspectives and impartial oversight. In June 2025, Brigitte Daurelle (independent director and former CEO of Euroclear Belgium, France, Netherlands) and Ryo Terazawa (Deputy Head of Transaction Services at MUFG Bank) were appointed to the board.[36] Chaired by non-executive director Gottfried Leibbrandt since May 2022, the Board focuses on strategic direction, risk governance, and compliance.[37] It operates through specialized committees, such as the Audit and Finance Committee (chaired by Karen Keenan), which oversees financial controls and internal audits; the Risk Management Committee (chaired by Sheryl Kennedy), which monitors credit, liquidity, and operational risks; and the Chair’s Committee, which handles remuneration and nominations to promote accountability.[30] Senior management supports the CEO through an Executive Management Committee, featuring key roles filled by professionals with extensive FX industry experience. The Chief Financial Officer, Trevor Suarez (appointed January 2015), manages financial planning, treasury, and reporting.[38] The Chief Transformation Officer, John Hagon, leads business development and client experience. The Chief Information Officer, Thomas Barkhuff, leads technology strategy and innovation for settlement systems. Additionally, Andrew Cooper serves as Chief Services Officer, directing CLSSettlement and processing solutions, while Deborah Hrvatin, as Chief Risk Officer, ensures robust risk frameworks across FX activities.[30][39] CLS Group's governance principles align with Principle 2 of the Principles for Financial Market Infrastructures (PFMI), emphasizing transparent, independent decision-making and accountability to support its role as a systemically important financial market infrastructure.[25] The leadership structure maintains independence from shareholders while fostering collaboration, with the Board and management collectively addressing operational resilience and market needs. The leadership operates under the oversight of central banks through the CLS Oversight Committee.[19]Supervision and Oversight
CLS Bank International, the primary operating entity of CLS Group, is regulated and supervised by the Federal Reserve Bank of New York (FRBNY) as its lead supervisor, operating under the authority of the Federal Reserve Board as an Edge Act corporation.[40][41] This supervision includes ongoing monitoring to ensure the safety and soundness of CLS's settlement activities, with the FRBNY coordinating examinations and regulatory oversight.[42] Since its launch in 2002, CLS has been subject to a cooperative oversight arrangement involving central banks from jurisdictions of its eligible currencies, formalized through the Protocol for the Cooperative Oversight Arrangement of CLS.[43] This protocol, administered by the CLS Oversight Committee chaired by the FRBNY, facilitates mutual assistance and shared assessments among 23 participating central banks—representing the 18 CLSSettlement-eligible currencies plus five additional Eurosystem central banks—to promote the system's stability and efficiency.[44][45] The committee conducts regular reviews, including evaluations of proposed changes to CLS rules and operations, to align with international standards and avoid policy inconsistencies across jurisdictions.[43] CLS complies with the Principles for Financial Market Infrastructures (PFMI) established by the Committee on Payments and Market Infrastructures (CPMI) and the International Organization of Securities Commissions (IOSCO), undergoing annual examinations by the FRBNY and rigorous stress testing to assess resilience against operational and financial disruptions.[25][43] These assessments ensure CLS maintains adequate resources and risk management practices, with results shared among oversight participants.[46] In July 2012, the U.S. Financial Stability Oversight Council (FSOC) designated CLS Bank International as a systemically important financial market utility (FMU) under Title VIII of the Dodd-Frank Act, recognizing its critical role in reducing settlement risk in the foreign exchange market and subjecting it to enhanced supervisory standards.[25][47] This designation reinforces the FRBNY's lead role while enabling coordinated oversight with other regulators to mitigate systemic risks.[48]Operations and Services
CLSSettlement
CLSSettlement is the core foreign exchange (FX) settlement service provided by CLS Group, designed to mitigate settlement risk through a payment-versus-payment (PvP) mechanism. This system ensures the simultaneous settlement of both legs of an FX trade—the payment of one currency against the receipt of another—eliminating Herstatt risk, or principal risk, where one party might default after the other has fulfilled its obligation.[49] The PvP process operates across global time zones using a structured cut-off time system, where trade instructions must be submitted by specific deadlines aligned with the operating hours of participating central banks, allowing for coordinated real-time matching and settlement within a single day.[49] A key feature of CLSSettlement is its multilateral netting process, which compresses a large volume of gross payment obligations among multiple participants into significantly smaller net positions. This compression reduces the liquidity requirements for settlement by approximately 96% on average, enabling members to fund only their net obligations rather than the full gross amounts.[50] The service supports settlement of spot FX trades, forwards, and swaps in 18 eligible currencies, including the Australian dollar, Canadian dollar, euro, and U.S. dollar, among others.[51] Operationally, CLSSettlement members—primarily major financial institutions—submit FX trade settlement instructions to CLS Bank via the SWIFT network, typically through standardized messaging protocols. CLS Bank then matches these instructions, calculates net positions through multilateral netting, and holds intraday funding in participants' accounts to cover potential obligations. Final settlement occurs via simultaneous debits and credits across CLS Bank's accounts at the relevant central banks, ensuring PvP execution and the release of funds only upon confirmation of both legs.[49] This process is accessible not only to the over 70 direct settlement members but also to more than 38,000 third-party users, such as funds and corporations, who route instructions through member institutions.[52] In terms of scale, CLSSettlement handled an average daily settlement value exceeding USD 7 trillion in 2024, reflecting its central role in global FX markets and a post-T+1 securities settlement increase to around USD 7.6 trillion per day in the latter half of the year.[53]CLSNet and Processing Solutions
CLSNet, launched in 2018, is an automated bilateral payment netting calculation service designed for foreign exchange trades ineligible for CLSSettlement, enabling participants to offset obligations between counterparties and significantly reduce gross payment volumes.[5][54] By standardizing post-trade processes across over 120 currencies—including major and emerging market ones like the Chinese offshore renminbi (CNH) and Thai baht (THB)—CLSNet mitigates operational risks, optimizes intraday liquidity, and lowers costs associated with funding, payments, and credit exposure.[54][55] The service operates as a centralized platform, calculating net payment instructions that participants can then settle bilaterally outside of CLS's multilateral framework, thereby extending netting benefits to a broader range of FX activity.[56] Adoption of CLSNet has accelerated in recent years, with eight of the world's top ten banks participating as of 2022 and ongoing expansion to include regional banks, asset managers, corporates, and non-bank financial institutions.[54] In the third quarter of 2025, the service processed an average daily netted value of USD 176 billion, marking a 10% year-over-year increase and reflecting heightened usage amid volatile market conditions.[28] A record single-day netted value of USD 620 billion was recorded in 2024, underscoring its scale in handling non-settled FX flows.[57] Since its inception on a distributed ledger technology platform developed with IBM, CLSNet has incorporated enhancements such as improved automation and connectivity options in the 2020s to facilitate seamless integration with participants' existing systems.[56] Complementing CLSNet, CLS Group's processing solutions include tools like CLSTradeMonitor, a post-trade monitoring and reporting application that delivers a consolidated view of all trade instructions submitted to both CLSSettlement and CLSNet.[58] This tool supports trade validation, reconciliation, and exception handling by providing real-time visibility into instruction statuses, helping participants identify discrepancies and reduce operational inefficiencies across their FX portfolios.[58] CLSTradeMonitor integrates with third-party settlement providers and internal systems, enabling broader market users—such as asset managers and corporates—to monitor non-CLS eligible trades alongside settled ones without dependency on specific infrastructure.[59] Introduced in 2018 and enhanced with automation features in subsequent years, it promotes standardized workflows and risk management for over 35,000 third-party entities indirectly benefiting from CLS services.[59][60]Data and Analytics Services
CLS provides data and analytics services through its CLSMarketData and CLSReporting products, leveraging executed FX trade data to offer market intelligence and support compliance needs. These services draw from CLS's position as a central hub for FX settlement, processing over 50% of global FX traded volumes across 18 currencies and encompassing data from more than 3 billion trades since 2011.[61] The datasets enable users to gain insights into FX market dynamics, including volume, liquidity, and trade flows, without delving into operational settlement details. CLSMarketData is a suite of alternative FX datasets designed for benchmarking, market analysis, and regulatory reporting. It includes aggregated metrics on FX volumes, liquidity, and outstanding positions, derived from diverse market participants such as banks and non-banks. For instance, the FX Volume dataset covers spot, swap, and forward instruments across various tenors, providing an unparalleled view of market activity. These tools help clients benchmark their performance against industry standards and monitor liquidity trends.[61][62] A key component of CLS's analytics output is its monthly FX Trade Volume Reports, which publish global FX activity metrics. In January 2025, average daily traded volume reached USD 2.22 trillion, marking a 6.2% increase from January 2024. Similar reports for subsequent months, such as April 2025 with USD 2.54 trillion (up 17.9% year-over-year) and September 2025 at USD 2.62 trillion, highlight ongoing market growth and volatility patterns. These publications serve regulators, policymakers, and market participants for assessing systemic risks and economic indicators.[63][64][65] For compliance, CLS offers data feeds through CLSReporting, an end-of-day report of matched FX instructions that supports regulatory obligations like MiFID II transaction reporting. It includes critical details such as legal entity identifiers, execution timestamps, and product classifications, aiding in post-trade transparency, risk management, and counterparty oversight. While not exclusively focused on anti-money laundering or trade surveillance, these feeds enhance overall compliance frameworks by reducing data gaps and duplicative reporting.[66] Data and analytics products are delivered via APIs for real-time integration, downloadable files for batch processing, and interactive dashboards for visualization, catering to needs of financial institutions, regulators, and analysts. This multi-format approach ensures accessibility and efficiency in utilizing CLS's high-quality, executed trade data.[4]Eligible Currencies
CLSSettlement supports 18 eligible currencies, for which CLS maintains accounts at the respective central banks or monetary authorities.[51]| Currency | ISO Code | Central Bank/Institution |
|---|---|---|
| Australian dollar | AUD | Reserve Bank of Australia |
| Canadian dollar | CAD | Bank of Canada |
| Danish krone | DKK | Danmarks Nationalbank |
| Euro | EUR | European Central Bank |
| Hong Kong dollar | HKD | Hong Kong Monetary Authority |
| Hungarian forint | HUF | Magyar Nemzeti Bank |
| Israeli shekel | ILS | Bank of Israel |
| Japanese yen | JPY | Bank of Japan |
| Korean won | KRW | Bank of Korea |
| Mexican peso | MXN | Banco de México |
| New Zealand dollar | NZD | Reserve Bank of New Zealand |
| Norwegian krone | NOK | Norges Bank |
| Pound sterling | GBP | Bank of England |
| Singapore dollar | SGD | Monetary Authority of Singapore |
| South African rand | ZAR | South African Reserve Bank |
| Swedish krona | SEK | Sveriges Riksbank |
| Swiss franc | CHF | Swiss National Bank |
| US dollar | USD | Federal Reserve Bank of New York |