At present, the FSA's Statements of Principle in APER apply only to the extent that a person is performing a controlled function for which approval has been sought and granted (see APER 1.1.2G). The new Financial Services Act 2012 ("the Act") permits each of the FCA and the PRA to issue Statements of Principle that apply not only to a person's controlled function, but also to activities outside such function.

Unsurprisingly, both the FCA and the PRA intend to issue Statements of Principle that extend to any activities beyond the scope of an individual's approvals. In broad terms, the proposal is to extend them for approved persons to any function in relation to regulated activities by the firm that that person carries out, whether or not the person is in so doing carrying out a controlled function. In its consultation paper, the FSA states that this could be seen as a significant change. However, it says that it does not in reality regard it as such because it would expect individuals always to apply the same standard of behaviour in their wider roles. That may well be what the regulators assert. However, in practice, what it clearly does is to widen the range of behaviours for which approved persons may be accountable, and increases the regulators' ability to punish them. Although not quite the same, the issue has some similarities with the debate about the regulators' argued limited ability to pursue individuals in relation to LIBOR shortcomings (see Enforcement Watch 8 "What is to come in relation to LIBOR").