On November 26 2015 the Financial Conduct Authority (FCA) announced1 that it had fined Barclays Bank £72 million for failing to minimise the risk that it may be used to facilitate financial crime. The failings related to a £1.88 billion transaction that Barclays Bank had arranged and executed in 2011 and 2012 for a number of ultra-high net worth clients. The clients involved were politically exposed persons and should therefore have been subject to enhanced levels of due diligence and monitoring by Barclays Bank.

On December 16 2015 the FCA2 and Prudential Regulation Authority3 published final rules confirming how they will apply the new accountability regime to individuals working in UK branches of overseas banks, having published4 on July 7 2015 the final rules confirming the approach to improving individual accountability in the banking sector. The final rules cover the Senior Managers Regime, the Certification Regime and the new Conduct Rules. The rules are the latest changes aimed at embedding personal accountability in the culture of financial services and constitute a crucial step in rebuilding public trust.