In April, the FCA announced that it had commenced an enforcement investigation into the IT failures at RBS Group (which include NatWest and Ulster Bank) which affected the Bank’s customers (particularly those banking with Ulster Bank) in June and July 2012. We await to see the outcome of this. In light of Martin Wheatley’s comments that the management of firms need to be held to account (see elsewhere in this edition "Is punishing individuals how the FCA intends to achieve real deterrence?"), what may be particularly interesting is what the result of any enforcement action will be for those relevant individuals with senior management posts.