On 23 May 2014, the FCA fined Barclays £26,033,500 (Stage 1: 30% discount) for failing adequately to manage conflicts of interest between itself and its customers in relation to the London Gold Fixing process, in breach of Principle 3 (Management and Control) and Principle 8 (Conflicts of Interest). The FCA determined that there were failings at Barclays from 2004 until 2013, but that the key event occurred on 28 June 2012, when former Barclays trader, Daniel James Plunkett, exploited the weaknesses in Barclays’ systems and controls to seek to influence that day’s 3:00 pm Gold Fixing, thereby profiting at a customer’s expense. Barclays had subsequently voluntarily recompensed the customer for any losses and had also brought Mr Plunkett’s behaviour to the attention of the regulator promptly. The FCA also fined Plunkett £95,600 (Stage 1: 30% discount) and banned him from performing any function in relation to any regulated activity for breaches of APER, Principles 1 and  3.  Against the  background  of  other  prominent  benchmark investigations, Tracey McDermott, the FCA’s director of enforcement and financial crime, commented: “We expect all firms to look hard at their reference rate and benchmark operations to ensure this type of behaviour isn’t being replicated. Firms should be in no doubt that the spotlight will remain on wholesale conduct  and  we  will  hold them to account if they fail to meet our standards”.