ACI Russia eFX Summit 2020. Panel 2. Role of Central banks in the functioning of FX market.

Moderator: Sergey Romanchuk, Head of Trading, Metallinvestbank, President of ACI Russia

Panelists:

Guy Debelle, Deputy Governor of the Reserve Bank of AustraliaChair of Global FX Committee (online);

Valery Lyakh, Director of the Bank of Russia’s Department for Countering Misconduct;

Dmitry Piskulov, Head of FX Market Product Development, Moscow Exchange, ACI Russia Vice President;

Russell Lascala, Global Head FX Trading, Deutsche Bank (online);

  • Central Bank instruments and facilities. Regulation or self-regulation?

  • Role of the Global FX Committee (GFXC) in the global and regional context. 

  • Problems with the Global Code implementation in the practices of the largest clients in FX market. 

  • GFC working groups directions to develop the FX Global Code: buy-side outreach, anonymous trading, disclosures, algorithmic trading, TCA, execution principles

  • Analysis of flash crash events and prospects of algorithmic trading regulation. 

  • FX fixings: instruments of the future or the past?

Sergey Romanchuk, Head of Trading, Metallinvestbank, ACI Russia President:

The next panel is about the way the FX market is regulated or self-regulated. I am inviting Dmitry Piskulov, who is head of FX market product development of Moscow exchange. Also with us we should have Valery Lyakh. Can we ask Valery to come to the panel?

And online with us we have two foreign participants, Guy Debelle, Deputy Governor of the Reserve Bank of Australia, Chair of Global FX Committee. We should also have online Russell Lascala, Global Head, FX Trading, Deutsche Bank.

I would ask you to show our Zoom session on the screen. I hope our foreign colleagues are with us already. Valery, please take your seat over here. What about Zoom? While we are waiting for our foreign colleagues to get connected, let us open the discussion with those we have here offline. We thought Guy Debelle would be opening the session. Guy, do you hear me?

Guy Debelle, Deputy Governor of the Reserve Bank of Australia, Chair of Global FX Committee (online):

Yes, I do. Thanks.

Sergey Romanchuk: Great. Sorry, we are a little bit late with our first panel. Sorry for this delay. We are very happy to see you here in Moscow. The hall is, of course, half-empty. But a lot of participants are online. Unfortunately, the pandemic trend in Moscow is a little bit scary. This is why we have more of a studio for the virtual event than a real offline event as we usually have for eFX Summit in Moscow. So on the stage you can also see Dmitry Piskulov from MOEX and Valery Lyakh from the Central Bank of Russia.

First, I would like to ask you to start this panel with your message as the Chair of Global FX Committee, which Russia joined last year. It is proud to be part of this membership.

It is your turn to to start the panel and tell our audience how this work is done, what are the actual programs and what is the main focus for the global FX and how it will help to provide integrity on FX market with self-regulation. Or probablyyou think that at the national levels there should be some regulation of FX markets or even globally? Please now it's your turn to start. Thank you.

Guy Debelle: Thanks very much, Sergey. I apologize that the sun has decided to set in my face as I am starting to talk here. But I am very pleased to have the opportunity to speak to you all in Moscow virtually. Sergey has kindly asked me to come to Moscow in person a few times. I have yet been unfortunately to make it.

As Sergey says, I am the chairman of the Global FX Committee. I have been so for the last year or so. But prior to that, I'd led the group which actually set up the FX Global Code for two or three years. So I was very much was involved inputting the FX Global Code into place three years ago.

Now let me just talk to you a little bit about the Global FX Committee, GFXC. It's a mix of both public sector and private sector as half and half on the GFXC. We have 20 member countries, 20 member FX committees from around the world,including obviously the Russian one. We have a mix of G10 currencies but we have also a bunch of emerging currencies as well, including the RMB, India, Brazil, Korea, South Africa, a wide range of countries from across the world.

Each committee is represented on the GFXC by a central bank representative and by a representative from the private sector in terms of the FX market. And within the private-sector representation, we have a broad representation from the sellside, the buyside, platforms, some major non-bank players as well. So we try to ensure that the whole breadth of the market is covered by the GFXC.

We have met three times already this year, virtually. At each meeting we discussed what's going on in the FX market in terms of market functioning, compared notes and experience.

One issue we talked about a number of times which may be relevant to you all is that we have had quite a few discussions around benchmark fixes, which has been a long-standing focus of the committee since its inception and going back even before that.

The GFXC engages with WM, Refinitiv these days, WM/Reuters, which runs the London 4PM fix as well as all the otherFX fixes. I was on a call with them last night. Actually, about this time last night. This time yesterday, your time.

We are talking to them about some of the concerns that some of the market participants have had with benchmark fixes and ensuring that WM is aware of them and encourage them to be much more engaging with the market participants.

I was reasonably encouraged by what they said last night: that they are going to increase the profile, engage more with market participants, potentially provide more data around the fixes to market participants as well. It is something which,hopefully, would be a more positive development going forward.

That said, one thing I would encourage you all when you are thinking about using fixes is that you are using them for the right purpose and that you understand why you are using them, and how your orders are being handled around the fix and particularly around the month and quarter end.

And just be aware of the potential risks and volatility that can occur around that. That’s one of the topics we have beenpicking up in terms of market function over the last while.

Let me talk a bit about the FX Code. It's been in place, as I said, for a bit over three years. We have over a thousand people who had signed the statement of commitment to the FX Code, including some participants in the Russian FX market. I actually think it has had an impact in improving market function, particularly compared to where we were prior to the Code.

One of the main aims we have been trying to reach with the Code is to have just one Code across the whole FX market.

So as you may be aware there was the ACI Model Code, a lot of which is reflected in the FX Code. But there are number of different codes of conduct used by different markets.

The ACI Code was used in Russia, in the Australian market, but it wasn't used in places like New York or London, where they had their own codes or none at all in the case of New York. There really was a desire to have one code to reflect the fact that there is one global FX market and that's what we have.

It's a Code of 55 principles. It is principles-based. It is not a regulation. We are not regulators. I'm a central bank but at least in Australia I am not a regulator. I am a market participant. The Reserve Bank of Australia is a reasonably large market participant in the Australian FX market. But we are not a regulator of the market.

So the Code is a principles-based code. I think it is pretty straightforward to read. It is not a black letter regulation. I think that is appropriate for the FX market because there's a lot of gray in the FX market, which doesn't suit well to black letter regulation.

At least, my experience is, the more you try and get prescriptive around the FX market, the less successful you are. Hencethe fact that the Code is principles-based.

That said, in a few jurisdictions, like mine, like Australia, the securities regulator here uses the FX Global Code in itssurveillance of market participants. And a similar situation occurs in London with the with the FCA.

So the Code, as I said, is principles-based. We launched it three years ago. It has been over three years ago now. We said that we would update the Code every three years to ensure that it remains consistent with the evolution in the FX market and that's the process we’re in the middle of now.

So I will talk a bit about that and then Russell and Dmitry will pick up some of the other points as they are involved in some of the groups which are looking at various aspects of the Code.

So we’re reviewing the Code, but we are not going to change it substantially. The feedback we got from market participants is that it remains fit for purpose, it's working in the market. Most people are comfortable with the bulk of it.

There are a few areas where we need to keep moving ahead as the market is moving ahead – around anonymous trading and around some issues, around some of the platforms.

There are some areas where we don't think market practice is as good as it could be. Disclosure documents that mostly banks put out… not all of them we think hit the mark and we do think there is room for improvement there. That is one ofthe other issues we’re looking at.

The other area we’re looking at, which Russell will probably pick up on, is around some of the trading practices which have been always contentious in the market and remain so.

Most notably, pre-hedging and last look. We did not necessarily land them exactly right the first time. I think we did a reasonable job. That is somewhere where there continues to be a lot of discussion. We are looking at them again. I don't think we can change them particularly but it is an area of focus.

And the final area I will talk about before turning to the next speaker, an area we talk a fair bit about is settlement risk. It has been an issue, most obviously, in Turkey and Argentina in recent times. That is an area where we think we can bring it the people's attention.

There is the BIS triennial data on FX market turnover that looks like there is a lot more FX transactions which don’t go through PvP settlement processes. As a result, there may substantial FX settlement risk out there.

So we are highlighting that issue, reminding people that settlement risk is a thing and something you need to be aware of. It can obviously entail a pretty large risk if it isn't handled appropriately.

That is one thing we are doing: we are reminding people of it and looking at the way we cover that in the Code and seeingif there're some areas which we can tighten up as well.

These are the areas of focus. They are around trading, settlement risk, anonymous trading, disclosure, and algo execution, something which is a lot more prevalent today. These are the areas of focus. The Code is not going to change substantially.

If you haven't signed it or if you haven't had a look at it, I would encourage you to do. It is fairly easy to get your head around. It is not that hard or long.

I would focus on the areas which are most relevant to the way you engage with the FX market. I would stronglyencourage you, if you haven’t already, to think about signing up to the Code so that we can ensure we have a well-functioning FX market right across the globe.

Sergey, let me finish there and hand over to the next speaker.

Sergey Romanchuk: Thank you, Guy. I have one question for you from our audience but before I ask you, can we show our poll today on our online platform. We can ask people about different topics for this panel so I would like to ask you.

Do you think that participants in the FX market should regulate themselves through voluntary adherence to the principles of the FX Global Code? Or would you consider FX as a financial instrument which needs strict regulation by the authorities?

People will be answering to these questions and I will change a little bit this question and address it to Guy, if possible.Could you also show the Zoom screen? We will come back to the results of this poll at the end of the session.

Guy, what is your opinion as the Chair of the Global FX Committee to the ESMA consultation paper on the provisions of the market abuse regulation? That’s quite a hot topic. The inclusion of FX as a financial instrument in MiFID II will lead to big changes in the market and a big burden to all the participants. ACI has prepared an answer to the consultationpaper. Probably you have seen it. What is your opinion?

Do you think that probably the Global FX Committee could react somehow to express its opinion as a committee of central banks, which could be probably more heard by the regulators than just the market participants’ voice? What do you think?

Guy Debelle: I have been in direct engagement with ESMA as the chair of the committee earlier in the year. I will be speaking to them again in a couple of weeks’ time on exactly this issue. It is slightly difficult for us to speak as thecommittee. We have the ECB and whatever on the committee, which makes a little more challenging. But as I am speaking to them as chair of the committee… there are a couple of points I make to them.

One, they have got to be mindful of the fact that the FX market is a global market and trying to regulate it in a local jurisdiction I think is challenging because of the huge breadth of market players from right around the globe that will be trading with people in the eurozone.

I'm not sure that they fully appreciate the consequences of that. Or maybe they appreciate but I am not sure they realize how challenging it potentially could be.

The second point, which is what I said earlier. I don't think the FX market is particular well-suited to black letter regulation. The way it's approached in Australia is that the market participants are regulated in terms of being market participants, regardless of whether they are in the FX market or any other market. If you do something wrong, your license is potentially at risk. But it's not black letter regulation of the FX market per se.

I do think that doesn't really work. I think it will be almost impossible to come up with black letter regulations which actually work. That's why we have the principles-based approach in the Code.

That's why regulators like ASIC here in Australia, our securities regulator, and the FCA in the UK reference the code in the way they assess market participants, market conduct, but they don't try and go for black letter regulation. I don't think that's the right solution. Market participants need to be held to account if they are doing the wrong thing, but I don't think it is by black letter regulation.

I think is more around, you know, if you're not following the principles in the Code, then what our securities regulator does here… it has capacity to suspend your financial services license as reasonable penalty.

That sort of approach I think is going to be more workable than trying to come up with a regulation for a market which is global in nature.

Sergey Romanchuk: Thank you, Guy. I would like to switch to our panelists here at Lotte Hotel. Valery, as head of the Bank of Russia Department for Countering Misconduct, what is your view of the market regulation? Are you satisfied with the current situation on FX market? What are the tools you would like to implement?

Should we anticipate any threats or initiatives like those in Europe concerning the regulation of the FX market? What do you think about that? How can the FX Global Code based on principles be applied in Russia?

Valery Lyakh, Director, Bank of Russia’s Department for Countering Misconduct:

Thank you very much for your question. Dear colleagues, offline and online, good morning to you.

Sergey, thank you for organizing this event. To see people offline today can be appreciated. I would like to give a disclaimer. I could not miss this event but we now have the so called week of silence. Whatever I say should not be interpreted as related to the Bank of Russia’s official monetary policy, particularly ahead of the pending announcement.

Here is what I think. Non-compliance by market participants with the code of conduct, with the FX Global Code, should become a disadvantage for them. On the contrary, acting in line with it should provide more benefits than if you just formally follow the rules. Adhering to principles could often be more costly than just following official rules in a formal manner.

My second point is about the cross-border nature of the markets and the FX market in particular. Compliance with the code gives market participants an opportunity to interact with their counterparts who have a different mentality.There are foreign players in the Russian market, and Russian participants are present in foreign markets.

Conduct is not just about formal procedures, it is also about mentality and the mindset. Codes allow you to understand the rules of the markets where you have not been present originally and you are only entering for the first time. It gives youthe framework as interpreted by the key players so that you don't go beyond those boundaries and principles.

Now on regulation. We are quite cautious about our market regulation. We will soon be implementing a new regulation for the stock market. Dmitry can comment on that more. We will be seeking to more or less limit the aggressiveness of stock market practices. Igor could have told you that it could be rolled out to other markets, too. That’s the current level of where we are.

Sergey Romanchuk: A couple of words about regulation generally? We have the MOEX Code but what about a more or less umbrella framework of the common code? How can it be applied in different markets?

Valery Lyakh: Yes, and it will be interesting for our foreign colleagues, too. Our principles-based high-level code of conduct is being discussed with various market participants, including at the market board. Right now we are putting together the key principles of this high-level code. It will be later adjusted to work at industry level and profession level.

The FX Global Code represents the third level of our Codes. We have a pyramid-type system, first the Code of Good Conduct, common for all markets and industries of the financial sector, then you have industry-level codes and professional codes. Last year, Russia helped CFA to create an instrument which is more or less like an ethics code for financial analysts. The NFA is gradually rolling it out.

We hope it would help to address some of the acute issues in the short-term. If there are any cases that would need to be resolved, they would be brought to the public attention in a transparent way. All the stakeholders would be able to clearly understand the principles behind the final decisions.

You may agree or disagree with the ruling but these decisions should be open and straightforward to understand.

Sergey Romanchuk: Thank you. Dmitry, can you tell us what is going on at MOEX? MOEX is the only Russianparticipant of the FX market that signed the statement of adherence to the FX Global Code.

Of course, we are working towards having more signatories among commercial banks. The Central Bank focused on that issue during our previous event in August. We will be expecting news from the Bank of Russia. We hope it will lead by example, which was earlier confirmed.

Dmitry, on the one hand, you represent MOEX, on the other, you are also a very active member of the working groups set up by the FX Global Code that include market participants. What is the most important aspect of your efforts both at MOEX and as part of the committee?

Dmitry Piskulov, Head of FX Market Product Development, Moscow Exchange, ACI Russia Vice President: Thank you, Sergey. I will speak in English. It is an international panel, after all. Yes, indeed, MOEX was the first Russian financial institution and exchange and an electronic platform that issued the statement of commitment to the FX Global Code back in July 2018 – more than two years ago.

As was said before, we are considered by market participants, both local, but most importantly, by international participants who trade at MOEX. 45% of our spot market comes from international participants.

They are quite eager to see that the dominant Russian-ruble liquidity pool which sets benchmarks for ruble trading, prices and order books has adhered to the Global Code.

So we issued the statement of commitment. I would not say that our activities are very thoroughly scrutinized. We have strict regulation from the central bank. Also, we have very profound rules, a rulebook and a lot of procedures.

So we adhere to the Code saying that we are compliant to it. We published it on our website. Since then, we expect that more institutions should come to issue the statement of commitment in the Russian market.

First of all, we expect that the Central Bank of Russia would do so. We are also part of ACI Russia, the local community,which promotes the FX Global Code and its principles. We’re going to offer some educational courses to the Central Bank, to the relevant personnel of the Central Bank so that they could evaluate and understand how to correctly apply the leading principles and the principles of the FX Global Code.

So we hope that we will not be the only institution in the Russian market and that more and more institutions will sign up to it. We also expect that large Russian banks will also join the FX Global Code.

This is about the Code, which is the cornerstone. We expect that these high-level best practices which are written in the FX Global Code will be implemented and employed by the local participants.

I would like also to comment on Sergey’s question. I participate in one of the working groups of the Global FXCommittee. This is the working group on anonymous trading. Why? Because MOEX used to be an anonymous trading platform for many, many years since we use the Central Counterparty and the National Clearing Center as thecounterparty for all buyers and sellers. They do not know the names of each other, all trades are done via the CCP.

In the classification which is made by GFXC we see that there is a fully disclosed mode of transacting when the counterparties know each other before the trade, and fully anonymous modes like in our case, and in-between there aresemi-disclosed and semi-anonymous modes. We also understand that these are the trends in the international market.

We also moving to new principles, to new products in our product line at MOEX. E.g., last year we launched a new product which is called ‘request for stream.’ We call it RFS shortly. It uses tags. One of the most important questionsanalyzed and discussed by the anonymous working group is information sharing and the use of confidential information in tag management and when we use tags.

Of course, it is a challenge to us because tags make us semi-anonymous. In this process, we use the tags of liquidity consumers or the takers and we should disclose them very cautiously. They should understand that we need to respect their identity and anonymity. They expect us to have anonymity.

That's very much in line with Principle 19 which says that market participants should clearly and effectively identify and appropriately limit access to confidential information. They want confidentiality.

And we are facing a question, to what extent it should be reflected in our rulebook, in our procedures. As I said, it is important for our liquidity consumers and for market makers, liquidity providers when they assess their market impact.

There are a few other streams of work in the anonymous working group. One is quite close to disclosure and information sharing. For instance, the use of post trade data is very important both for the venue to analyze the behaviors of its market participants, its players, and to liquidity providers to optimize the pricing they provide to liquidity consumers to make it efficient and, especially, for liquidity consumers which need the post trade data to optimize the liquidity they receive from liquidity providers and to benchmark the performance of liquidity providers to reach the best execution.

This is especially important with the development of artificial intelligence and machine learning. That topic will be discussed later during this conference. Proliferation of modern technology makes the ability of liquidity providers to digest the data they receive from venues in a way that should not be harmful and shouldn’t be to the disadvantage of liquidity consumers. E.g., in such areas, such as fill ratios and reject rates and shutoff from the liquidity. We feel that all these items are quite important.

One of the other issues that is being discussed is cross-venue credit checks. It is quite a new thing. We know that many market participants allocate their limits on the venues on each client through trading through each venue on a gross basis. They are allocated on each client on each venue. This is especially important because some clients work through their FXprime brokers. So there is a need to use a specific technology, IT solutions that can monitor the utilization of the limit per client, per trading venues in a more efficient way.

This is important from the risk management point of view. The current situation leads, first of all, to excessive use of the limit and, second, to overcollateralization. That is why this is important. Modern IT solutions provided by some vendors may solve these problems.

I told you just about the anonymous trading working group of FX Global Code, which is producing its materials to raiseimportant questions in the further development and improvement of the FX Global Code. We appreciate very much the other streams at GFXC such as buyside outreach, disclosures, execution and some others.

Sergey Romanchuk: Thank you, Dmitry, time is quick. You have fully described your work. I would just add that Dmitry is also a member of the Moscow FX joint standing committee where we discuss those issues and do the homework before the Global FX Committee meetings.

Now it's time to ask Russell. How did adherence to the FX Global Code help Deutsche Bank to serve their clients and probably to gain a market share? What is your experience as a global FX provider?

Russell Lascala, Global Head FX Trading, Deutsche Bank (online): Thank you, Sergey, can you hear me okay?

Sergey Romanchuk: We can see and hear you.

Russell Lascala: Thanks so much for inviting me to speak today. These events are always easier and actually a lot more enjoyable in person but bringing together the FX marketplace on Zoom is also pretty cool.

I'm honored to be invited to speak on the central bank panel. Deutsche Bank and the Central Bank of Russia have a very long history together. The Russian market is one of the biggest in Europe so this is important. Thank you for organizing it.

Let me just begin before I answer your question with a few words about the code of conduct. As Dmitry mentioned, beinga part of these working groups is very critical. When you represent FX committees around various regions, you're always trying to bring together the best outcome for all the market participants.

The regional aspect, as you mentioned earlier, on the GFXC is extremely valuable when considering the execution best practices of FX globally. As Guy mentioned, GFXC has been very flexible to allow for regional considerations within the FX Global Code while also maintaining the integrity of the principles-based code, which I think adds to your comment earlier about regulation and rules-based. Getting this high-level document correct without being too high level is really the art of what were all trying to achieve here on the Global Code. What would not work, in my opinion, for this industry is explicit rules-based code that tries to cover each region’s nuances.

The Global Code is mostly not regulation, as Guy mentioned, but best practices. But I think it's important to understand the Code does apply to all. It is intended for all market participants, whether they are corporates or banks or hedge funds,HFT firms.

Recognizing that while the code applies to all the details and precisely how we have differences, I think it is really important that we have come together as an industry to get this feedback so that we can have a proper review. Here we are three years later post the Code launch doing this review to see if we do need any enhancements to the Code.

Like Dmitry, I'm also on the working group for reviewing three areas within the code: last look, pre-hedging, and riskless principal or agency type of execution. Let me give you an update on where we are on these working groups.

Last look. This group is focusing on drafting a paper which will clarify the mechanisms of last look. This paper,hopefully, can be utilized also as an educational resource among market participants.

Disclosures are very critical for us bringing up the code on each review process and I think the details around disclosure will be an important part of this process. I can almost imagine us coming up with standardized templates that are very easy to understand and that give disclosures around the mechanisms of each liquidity providers last look details.

Secondly, it is pre-hedging. This is a tricky one, but I am very proud that the code tackled this in the beginning three years ago and that we have a basis to form pre-hedging best practices. There has been a lot of input from both the sellside and the buyside here.

The focus is going to be on clarifying pre-hedging. Some of the areas we were discussing now is what pre-hedging is.Specifically, what's the difference between hedging and pre-hedging? Is this a functional risk transfer between the client and dealer or is it a function of the trade information, specific or nonspecific, or both?

Another very important part is, does pre-hedging apply to… disclosures. I think giving clients the ability to make informed choices is the best result for the FXC.

Lastly, just in summary of what we’re doing on the working group… we’re also talking quite a bit about netting and settlements as this is key to the safety of the overall market.

So in summary with respect to the code where we work hard, the FX Global Code is meant to be fit for purpose. So the three-year review makes total sense. Hopefully, changing it as the market evolves.

Signing the Global Code for Deutsche Bank was not that easy of a task in the beginning. Of course, we needed to review how FX applied globally to each regional nuance. But once we did that it was easy to come together and apply these principles and look to see if we have any gaps.

I can tell you now that clients are already asking us about the Global Code. And within our prime brokerage unit it's a specific question we are asked when we onboard a client. So I think as the Code becomes more and more adapted and more and more people sign the statement of commitment, this will be a normal practice.

Not actual regulation, but more of a best practice. “Have you signed the code?” Let me hand it over back to you.

Sergey Romanchuk: Thank you, Russell. It's a great speech.

Please if possible, can we show the results of our poll about self-regulation or regulation? The majority are in favour but for some people regulation by the authorities is more preferable.

The time of our panel went by but probably we have just a few minutes for final remarks. Guy, would you like to make asummary of what you heard and about the Russian market as well?

Guy Debelle: In listening to both Valery and Dmitry, it seems the Code is absolutely relevant for the Russian market.Dmitry talked at some length about how that is so, in particular, on the work we are doing on anonymous trading.

But the important thing to note is that FX market is a global market. Russia is an important part of that global FX market, as obviously, you're all aware. I think it is important that we have the same consistency of practice right across the whole FX landscape.

I think the FX Global Code does provide a benchmark for that consistency of practice. Hence I would really encourage local Russian market participants to have a look at the code and sign up to it in the same way that MOEX has. A lot of the other market participants, including, obviously, Deutsche Bank, have signed the Global Code.

I think it would be beneficial for the Russian market to sign up. I think it does provide a consistent and sensible way to think about the way you interface with the FX market.

Sergey Romanchuk: Thank you, Guy. Thank you so much for your opinion, distinguished panelists. Valery, would you like to add something?

Valery Lyakh: Yes. Colleagues, thank you very much for your participation. For us it is important to get together from time to time but also to look at the relevance of the codes, and this particular code, the Global Code and the issues which would allow us to attract in Russia a bigger number of participants, as Sergey said.

The Bank of Russia is on the path to sign the Code after special internal procedures. That process is underway. The COVID-19 lockdown had an impact on us. The procedures were not stopped, but suspended. But they are in the pipelineand we are going to bring them to an end and fully sign up to the Code.

Sergey Romanchuk: Thank you very much.

Valery Lyakh: And I urge everyone to sign the Code.

Sergey Romanchuk: Thank you, Russell. Thank you, Guy, for being with us today. Until the next meeting. Good-bye.

Guy Debelle: Yes, hope to see you in person.

Sergey Romanchuk: Yes, for sure.

Guy Debelle: Good luck.

Sergey Romanchuk: Good luck. Thank you.

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