On 15 May 2014, the FCA fined Martin Brokers (UK) Limited (“Martins”) £630,000 (Stage 1: 30% discount) for misconduct related to LIBOR. The FCA found that between January 2007 and December 2010, several brokers at Martins colluded with bank traders to manipulate the Japanese Yen LIBOR rates for profit. The FCA determined that the misconduct constituted improper market conduct (Principle 5 – Market Conduct) and occurred as a result of Martins’ inadequate systems, controls, supervision and monitoring (Principle 3 – Management and Control). The Final Notice contains (at paragraph 4.84 onwards) a useful list of compliance issues which the FCA identified. The FCA commented in a press release that Martins’ misconduct was exacerbated by a “poor compliance culture” as a result of its “heavy focus on revenue at the expense of regulatory requirements”. The FCA stated that Martins would have been fined £3.6 million, but due to Martins’ limited financial resources the penalty was reduced to £900,000 (which was in turn reduced to £630,000 as a Stage 1: 30% discount).