Bailey was speaking as he launched the FCA’s business plan for the 2019-2010 year in which he said the regulator would extend its senior management and certification regime. Currently, that only covers banks and insurers, but the new plan will see it extended to all firms. Bailey said this should avoid what has been dubbed the “Murder on the Orient Express” defence, where managers argue failures weren’t their own, but everybody’s, leaving no-one held to account.