Nearly two years since the introduction of the Senior Managers and Certification Regime (SMCR), there have been no prosecutions, limited evidencable enforcement and only a scattering of publicity. Taken purely on face value, it would therefore appear to offer much, but deliver little. Has it stopped a would-be Libor scandal? Has it scared potential rogue traders? Or are these nefarious acts still taking place as we speak, while regulators look on powerless to act?

The answer to that last question is, as always: possibly, but the chances are not nearly as high as before. Why? Because the true strength of the SMCR is that it encompasses so much more than the summation of its prosecution record. More than any other piece of regulation I have encountered, the SMCR is about one core theme - that individuals, especially senior ranking ones, be held wholly accountable for their decisions and, more importantly, the actions of those who work for them.