Resume af teksten:
Den forsinkede FX-rapport fra US Treasury, forventet i november, vil sandsynligvis fokusere på øget granskning af handelsaftalepartneres valutapraksis. Ingen lande forventes dog at blive udpeget som valutamanipulatorer. Thailand vil sandsynligvis blive tilføjet til Overvågningslisten, som også inkluderer lande som Kina, Tyskland, og Japan. Schweiz forbliver i fokus, især i forhold til interventioner udført af den schweiziske nationalbank. Rapportens højdepunkter omfatter tre temaer: dollarens nylige devaluering, fælles erklæringer om valutapraksis, og justeringer i Treasury’s tilgang til partnernes valutapraksis. Thailand og Schweiz siges at få markedsopmærksomhed, især med hensyn til interne diskussioner i Thailand om valutastyrke og økonomiske konsekvenser, og Schweiz’ utrættelige bestræbelser på at svække francen. Treasury’s ændrede tilgang kan påvirke fremtidige handelsaftaler og landenes opfattelse af valutainterventionernes nødvendighed.
Fra ING:
The November FX Report has been delayed but should be released soon. We expect an emphasis on the changing approach towards a tighter scrutiny on US partners’ FX practices, but we don’t think we’ll see any FX manipulator designation by Treasury. Thailand should, however, join the Monitoring List, and Switzerland will remain a focus point for markets
Source: ING
What is the FX Report?
The US Treasury’s semi-annual Report on Foreign Exchange Policies of Major Trading Partners (the “FX Report”) is expected to be released in the coming weeks, following a delay caused by the government shutdown. The report is prepared under two legislation:
The 1988 law requiring the Treasury to identify foreign exchange manipulators
The 2015 law introducing three quantitative criteria – thresholds have been revised over time – for evaluating trade and FX practices.
Criteria and thresholds
Source: US Treasury, ING
In this note, we estimate the current thresholds for these three criteria for the period covered in the Autumn FX Report: June 2024 to June 2025. Our baseline assumption is that a country is designated as an “FX manipulator” when it meets all three criteria. However, this is not a strict requirement, as Treasury can designate manipulators under the 1988 legislation even when not all thresholds are breached, like it did with China in 2019.
Each report also updates a Monitoring List for enhanced scrutiny, which includes countries meeting two criteria or contributing disproportionately to the US trade deficit. Removal typically requires failing to meet two criteria for two consecutive reports.
No country to be labelled manipulator
In June 2025, the FX Report concluded there were no FX manipulators, and expanded the Monitoring List, adding Ireland and Switzerland to the seven countries already present.
Our calculations (table below) suggest no country met all three criteria for June 2024–June 2025. While Treasury could still act at its discretion, we expect no manipulator designations in this Autumn 2025 report.
We, however, expect Thailand to join the Monitoring List, having breached the 3% of GDP threshold for current account surplus and therefore meeting the first two criteria. We don’t expect any countries to be removed from the List, which would then include China, Germany, Ireland, Japan, Korea, Singapore, Switzerland, Taiwan, Thailand and Vietnam.
Our estimates for the Autumn FX Report
Figures in red are above the criteria’s thresholds. Estimates are based on disclosed interventions when available or through the valuation-adjusted change in FX reserves, attempting to replicate the US Treasury’s methodology. *The Treasury usually reports China’s FX interventions both via an FX reserve calculation (first figure) and an FX settlement calculation (second figure) – we estimate both here ** Malaysia, Thailand and Vietnam convey intervention numbers privately to the Treasury, making it harder to estimate via FX reserves
Source: ING estimates, Macrobond, Central bank disclosures
Growing relevance of the FX report
FX practices have regained prominence in Trump’s second term. Ahead of this release, three themes stand out in our view:
1) Dollar depreciation
This Report covers a period of sharp dollar depreciation. While the 4Q rolling nature of the analysis includes the 2H24 dollar rally, it gives some initial indications of how US trading partners reacted to the weaker dollar, which is of great interest to the Treasury in its assessment of potentially unfair FX practices. This Autumn Report will be a good preview of the June 2026 edition, which will cover the whole of 2025 and will probably show higher intervention figures.
2) Recent FX joint statements
The US and some trading partners have issued joint statements on FX practices of late (table below). These are probably part of the Treasury’s intensified focus on FX practices through the lenses of tackling the large US trade deficit. At the same time, they could slightly reduce the chance of FX manipulator tags being handed out via the FX Report as the Treasury is already very active in direct FX discussions with central banks, likely based on up-to-date intervention estimates/disclosures. That said, the FX Report will provide an important update on how instrumental these joint statements are in the overall assessment of a country’s trade/FX practices.
3) Shifting approach by the Treasury
In the June 2025 FX Report, a few statements were added, remarking the shift in approach towards a higher scrutiny of trading partners’ FX practices. While admitting FX intervention had declined, the Treasury stressed “the damage done is long-lasting”, and the intent was to strengthen the analysis of trading partners’ FX practices by taking into account market dynamics. This Report can help form expectations of how important FX discussions will be for future trade deals.
Latest joint statements with US Treasury on FX practices
Source: ING, US Treasury, Central bank disclosures
Country focus: Thailand
As we expect no country to be named a manipulator, the market implications of the report should not be significant, in our view. However, Thailand joining the Monitoring List could grab a few headlines, particularly given the domestic discussion about the baht’s strength and its economic implications.
The joint statement between the Bank of Thailand and the Treasury reinforces the US scrutiny on interventions that can’t be justified as volatility smoothing measures. So far, the BoT would privately communicate the FX intervention numbers to the Treasury, and estimating them independently has proven rather challenging on our end. For this report, we estimate interventions will be 1.4% of GDP, but may well prove much closer to the 2% threshold. The BoT will have to disclose them semi-annually from now on.
THB and CHF have strengthened on a trade-weighted basis
Source: ING, BIS
Country focus: Switzerland
Markets will continue to look at the FX Report with interest when it comes to Switzerland. The recent joint statement on FX practices and the reduction of US tariffs on Switzerland have failed to address the Swiss National Bank’s longstanding conundrum: how to weaken the franc?
As shown in the table, we estimate FX intervention by the SNB at $7.4bn (or 0.8% of GDP) for the four quarters into June 2025, which are covered by this FX Report. However, $6.4bn of those happened in the first half of 2025, capping the room for further intervention in 2H25. But with rates at 0% and low appetite to return to negative, there is a strong feeling FX interventions are the only realistic measure to drive CHF lower.
Any change in wording about Switzerland in the FX Report will be scrutinised closely. In June, the Treasury mostly included some macro considerations on the country, with no major focus on FX practices and only a recommendation to increase government spending. If the Treasury sounds more lenient towards Swiss FX intervention – framed as a macroeconomic tool – CHF can take a hit. Conversely, a tighter approach could keep perceived FX intervention risk low and support CHF further.
Hurtige nyheder er stadig i beta-fasen, og fejl kan derfor forekomme.
