On 22 September 2022, the Financial Conduct Authority (FCA) published its consultation paper (CP 22/18, the CP) which proposes new guidance on the trading venue perimeter. The CP follows on from the discussion on this as part of HM Treasury’s Wholesale Market Review (WMR), which concluded that there is a need for greater clarity about what types of firms fall within scope of the definition of “multilateral trading facility” (MTF). This is particularly true in light of the spread of new technologies and systems that perform some of the functions conventionally associated with trading venues.