Following the 2008-09 financial crisis and scandals including PPI mis-selling and LIBOR manipulation, an enhanced focus has emerged from the UK regulator, the Financial Conduct Authority (“FCA”) on the behaviour and culture within financial institutions. The FCA is paving the way for a new regime, which uses "credible deterrence" by focusing on the responsibility of individuals in order to change compliance culture. In essence, the FCA has recognised that even large fines have failed to change the culture within banks so has shifted its focus to the senior individuals.