According to the Serious Fraud Office (SFO), the evidence presented to the jury showed that Mr Hayes repeatedly asked rival traders and brokers, as well as submitters in his own banks, to move the Japanese yen LIBOR submissions up or down to suit his needs, often by offering to reward them for their efforts.

Mr Hayes conspired with others to rig the submissions of Yen LIBOR rates, first at UBS between August 2006 and December 2009, and then at Citigroup between December 2009 and September 2010. He was sentenced to nine and a half years in prison for the UBS offences, and four and a half years in prison for those committed at Citigroup. The sentences are to run concurrently.

In sentencing Mr Hayes, Mr Justice Cooke surprisingly observed that the maximum sentence of ten years for a single count of conspiracy is generally recognised as too low given the seriousness of the offence. Less surprisingly, he stressed that high standards of honesty and probity should be expected from individuals who work within the banking system.

The SFO's criminal investigation into LIBOR rigging is only one part of the story. There are various investigations into benchmark manipulation, both in the UK and abroad, in respect of both firms and individuals.

Since imposing its first fine for LIBOR manipulation on Barclays Bank plc on 27 June 2012 for £59.5 million, the Financial Conduct Authority (FCA) (and its predecessor, the Financial Services Authority) has not held back in bringing enforcement action against firms for failings connected to benchmark rates.

The fine on Barclays was swiftly followed by the fines on UBS for £160 million on 19 December 2012, on RBS for £87.5 million on 6 February 2013, on ICAP Europe Ltd for £14 million on 25 September 2013, on Rabobank for £105 million on 29 October 2013 and, most recently, on Martin Brokers (UK) Ltd for £630,000 on 15 May 2014 (see News brief "RBS, LIBOR and another fine: the FSA broadens its approach"; www.practicallaw.com/3-546-0900; www.practicallaw.com/1-549-7947).

The fines on Martin Brokers and ICAP are, in many ways, the most significant. They warn firms outside of the major banks that they are just as likely to be targeted in the future. The FCA's focus on credible deterrence in its pursuit of better conduct within the financial services sector goes beyond banks, and has extended beyond LIBOR.

In November 2014, the FCA announced an industry-wide remediation programme in relation to foreign exchange (WM/Reuters London 4pm Closing Spot Rate) following a number of fines for failings related to the manipulation of certain other foreign exchange rates.

The fines imposed on firms to date have been largely based on breaches of Principle 3 (the duty to take reasonable care to organise and control a firm's affairs responsibly and effectively, with adequate risk management systems) and Principle 5 (the duty to observe proper standards of market conduct) of the FCA's Principles of Business. On 21 July 2014, the SFO opened a criminal investigation into allegations of fraudulent conduct in the foreign exchange market.

Mr Hayes's sentence, whether or not it is reduced on appeal, will be a salutary warning to traders, but in reality for the vast majority of those working in financial services this will appear to be no more than a matter of passing interest, in the self-assurance that they would never behave like Mr Hayes. However, firms should take note, not least because of the potentially draconian consequences should one or more of the regulatory and prosecutorial agencies pursue them.

Learn lessons from others. Despite the inadequacy of firms' systems and controls and the conduct failures highlighted by recent fines, the FCA's July 2015 report on its thematic review on financial benchmarks reveals that firms have not learned the lessons of the past.

The report presents the FCA's findings of its review on firms' oversight and controls in relation to financial benchmarks, which are, in short, disappointing. The FCA stated that despite the extent of historic enforcement action relating to benchmark failures, no firm had fully implemented changes across all benchmark activities. In particular, it identified deficiencies in firms' systems and controls and governance frameworks.

While the FCA has not suggested that further enforcement action will be taken, senior managers who oversee the relevant areas should be aware that it remains a distinct possibility.

Expectations on firms. Firms still have a long way to go to prove to regulators that a gap has been filled both culturally and in respect of their systems and controls, before the sector can be assured that individuals such as Mr Hayes will not be able to get away with similar conduct in the future.

To this end, firms should ensure that their "three lines of defence" are robust and that there is evidence of strong senior management, support and challenge from the second line of defence, with clearly defined roles and responsibilities and relevant oversight functions.

Expectations on individuals. The length of time over which Mr Hayes's offences took place also highlights the lack of awareness that senior managers had of what was happening on the shop floor.

Both civil and criminal regulatory authorities are heavily focused on individual accountability. In financial services, this is most notably demonstrated by the senior managers regime (SMR) and the senior insurance managers regime (SIMR) that will come into force in January and March 2016 (see Focus "Senior managers regime: strengthening accountability in banking"). These new regimes impose heightened standards of accountability on senior individuals and are designed to make it easier for the regulator to point to, and hold individuals to account for, regulatory failures.

While the severity of Mr Hayes's sentence may come as a shock to many, the criminal angle should not distract from the regulatory focus on conduct and culture. With the advent of the SMR and SIMR, even those who consider themselves not lacking in integrity need to be aware of their assigned responsibilities in the context of which employees they are responsible for.

The presumption of responsibility that will be brought into force with the SMR will mean that if something happens within a senior manager's remit, he will be held responsible unless he can show that he acted reasonably. These changes are likely to result in an increase in the number of individuals being investigated by the regulators, alongside the already apparent increase in criminal investigations.