1. Introduction The aim of this article is to critically assess the effectiveness of UK bank corporate governance reforms, in particular the recently introduced Senior Managers and Certification Regime (SMRC) and illustrate how it can be undermined. Part One will assess some of the future challenges in the implementation of the regime to support the argument that the regulatory reforms are not a sufficient mechanism to expose individuals and hold them accountable. The authors will criticise the effectiveness of the provisions on the allocation of responsibilities and collective decision-making and propose that the case law on the duties of directors under corporate law should be used as guidance for the implementation of the new regime. This part will also argue that although the new statutory ‘duty of responsibility' might not be as effective as it was intended to, it is a better option than the previously proposed ‘presumption of responsibility'. Part Two will argue that the presence of an unethical banking culture and various conflicts of interest incentivise individuals to circumvent the regime and undermine the effectiveness of the new Code of Conduct. Part Three reviews the UK remuneration reforms which forms another part of the UK mechanism to modify individual behaviour and align it with sustainable risk taking. Lastly, the authors will analyse the new rules on whistleblowing and argue that their ability to enhance the effectiveness of the regime by exposing inappropriate conduct can also be undermined. A banking culture of fear renders any internal whistleblowing arrangement nothing more than window dressing while the appointment of a Senior Manager as the whistleblowers' champion is not ideal considering the conflicts of interest with executive directors. Finally, the reforms introduced to modify behaviour through remuneration policy are also considered in their attempt to improve the governance of banks and minimise the risk of failure. 2. The Allocation of Responsibilities The regime intends to allocate each senior manager specific responsibilities which are going to be written down in the Statements of Responsibilities [1]. Although this is a welcomed attempt to rectify one of the weaknesses of the old regime, namely its failure to pinpoint a regulatory breach to an individual, the crucial issue here is how specific and narrow the language and nature of these responsibilities on paper is going to be. A growing number of individuals are already seeking independent legal advice on their rights and responsibilities under the rules and to represent them in the discussions with their firms. It is, therefore, neither unlikely nor unsurprising that their lawyers will pursue to limit for their clients the probability of a future liability as much as possible by ensuring that there are regulatory gaps that can be used in their favour. Indeed, there are ongoing attempts to “game” the system, and [continua..]