But Neil Williams of business crime solicitors Rahman Ravelli insists that no major conclusions should yet be reached about whether the banking sector exercises enough caution.

Britain's new system of banker accountability has led to improvements but further change is still needed, according to the financial sector's trade body.

UK Finance, the trade association for the UK's banking and financial services sector, has published the first major appraisal of the senior managers and certification regime (SMCR), which was introduced in 2016 as part of reforms implemented after the 2007-09 financial crisis.

SMCR makes it more straightforward for regulators to identify who is to blame when things go wrong. UK Finance said the report, which is based on a survey of 60 senior managers across 25 banking institutions, showed that banks are now more cautious about taking risks and are committed to implementing SMCR.

UK Finance added that SMCR has produced "a meaningful and tangible change in culture, behaviour and attitudes towards risk" by focusing senior managers' minds when it comes to individual responsibility. But it said that there was less evidence that others in such firms were acting with a similar focus; although lenders now have a clearer view of their roles and responsibilities.

Britain was first to implement such a system. But although it was introduced three years ago, it was not until 2018 that the first individual was punished under the regime. Barclays Chief Executive Jes Staley was fined £642,000 (and ordered to pay back £500,000 of his bonus) for trying to identify a whistleblower who had sent letters criticising a Barclays employee.

The Financial Conduct Authority has already made it clear that it considers the measurement of improvements in banking culture to be in its very early stages. While the report provides a helpful review of the progress so far - and indicates an apparent growing confidence in the regime by the banking industry - it would be wrong to reach any major conclusions yet.

Where sweeping changes are made, there needs to be certainty that they are having the desired effect and are effective against those they are designed to focus on. The report's findings should now serve to enhance the further effectiveness of the regulations moving forward.

Further reading: The Financial Conduct Authority: How It Functions And How Best To Respond To It

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