There will only be a change of culture in large corporate structures where individuals are held directly responsible for their actions to individuals and small businesses. Too many people in large corporations take significant risks knowing they will have little to lose. As it stands, many large corporations will be content to take risks where the gains outweigh the fine with no individual liability.
Senior decision makers of the bank, who carry out designated senior management functions, are to be allocated prescribed responsibilities. These are to cover matters relating to the firm's culture and standards in the different areas across the bank. The bank is required to have 'statements of responsibility' in place, which set out each senior manager's responsibilities. The aim is to ensure that if there is an institutional failing in a particular area of the bank, the relevant senior manager for that area is answerable to the regulators for that failing. The bank also has to produce 'responsibility maps', demonstrating to the regulator that there are no gaps in coverage.