When it comes to raising standards of culture and behaviour, the financial services industry is “not close to where it needs to be”. Thus said William Dudley , president of the New York Federal Reserve, last week and he is right. It is true that some banks are trying to drive through reforms root and branch. But others still claim that the problem is to do with a few bad apples rather than anything more systemic, and are relying on occasional town hall meetings with employees and a lot of top-down instructions to shift behaviour. That will not deliver the fundamental change necessary.

More bad headlines are to come. The full details of wrongdoing in the foreign exchange market have yet to emerge. And in some parts of the wholesale banking sector, it is beginning to feel as though nothing has been learnt from the crisis. Speculative market practices that were killed off when banks failed six years ago are starting to reappear.

Prime responsibility lies with the leadership of individual firms. Unless they are determined to change the culture of their business – to shape the implicit norms that guide behaviour in the absence of regulations – then nothing will happen. But there is a limit to what a firm can do by itself. As Lord Woolf wrote in his report on BAE Systems: “There may be some issues that are so pervasive or persistent within a particular sector that?.?.?.?the risk of reputational damage can only be addressed collectively.”