The penny, or whatever currency has just been rigged, may finally have dropped. Prime responsibility for rigging the foreign exchange markets rests with the coterie of dealers who were directly involved. But no one emerges unblemished.
英镑，或者无论何种刚刚受到操纵的货币，最终都可能贬值。虽然说操纵外汇市场的主要责任落在一小撮直接涉事的交易员身上，但所有人都难脱干系。
Professional traders smart enough to have worked their way into top positions at some of the world’s leading financial institutions were perfectly capable of understanding that fixing the fix was wrong. It was a benchmark on which many other financial valuations were struck, making the need for probity obvious to all market professionals. Ignorance is not a credible excuse.
那些足够聪明、一路爬上一些全球顶尖金融机构最高职位的职业交易员，完全能够明白，操纵定盘价是错误的。它是其他许多金融价值计算的基准，所有市场专业人士显然有必要在这方面保持诚实。无知不是令人信服的借口。

But if the dealers involved must take most of the blame, the Financial Conduct Authority is right to criticise the traders’ managers. The chain of command on trading floors runs up from senior dealers to desk heads, departmental managers and all the way up to the board. Front line controls are supplemented by oversight from risk managers and compliance officers. For all three lines of defence to have failed, in so many institutions, for so long, suggests an indigenous bias to optimism among those in charge: this was a systemic collapse of good judgment.
但如果说涉案交易员必须承担大部分责任，那么英国金融市场行为监管局(FCA)批评这些交易员的经理也是正确的。交易部门的指令链从高级交易员到交易主管、部门经理，最后一直向上延伸到董事会。除了前台控制以外，还应该辅以风险经理和合规人员的监督。长期以来这么多机构中的三道防线全都失效，表明了那些主管人员固有的乐观倾向：这是良好判断的系统性崩溃。
Banking regulators might also reflect on their mindset. They were busy saving the global financial system in the period from 2008 to 2013 covered by the fines, perhaps so busy that they failed to turn a critical eye on the system that had so recently failed the world economy. It took a whistleblower and some investigative journalism to do a job that regulators were meant to be doing and for all the high marks that the authorities now get for firm action in cleaning up the mess, they need to look very hard at themselves.
银行业监管机构或许也会反思自己的心态。它们从2008年到2013年忙于挽救全球金融体系，同时开出大量罚单，或许忙得都顾不上把批判的眼光投向最近让全球经济失望的金融体系。本该由监管机构做的事情，却由告密者和一些新闻调查人员做了。尽管有关当局现在由于采取坚决措施清理乱局而受到很高的评价，但他们有必要深刻地反省自身。
The direct evidence of market manipulation lies in the electronic trail from the dealers’ online chat rooms, but suspicious pricing patterns in and around the daily 4pm currency fix were obvious in hindsight. The BoE has its own dealers operating in forex markets; it appears that they failed to notice such patterns. This is a familiar story; they also failed to notice similar behaviour surrounding the Libor benchmark in the interbank lending market. Why?
操纵市场的直接证据在于交易员在线聊天室的电子痕迹，但事后来看，每日下午4点汇率定盘前后的定价模式也是明显可疑的。英国央行(BOE)在外汇市场有自己的交易员；他们似乎未能注意到此类模式。这听起来有些耳熟；他们也未能注意到围绕银行间借贷市场上伦敦银行间同业拆借利率(Libor)的类似行为。原因何在？
A meeting of BoE officials and senior forex dealers in 2006 discussed manipulation of currency markets. The fact that this discussion took place invites questions about what the Old Lady knew; the bank has conducted an independent inquiry and concluded that none of its officials were aware of market rigging. Although the BoE has a long history of generously interpreting its own actions – dating back to a whitewash Board of Banking Supervision inquiry into the 1995 Barings scandal and extending up to Libor – we must accept that none of its officials knew what was happening. That being the case, questions need to be asked about their competence. After all, the misconduct was detectable to journalists not directly involved in the market.
2006年，英国央行官员和一些高级外汇交易员召开会议讨论了外汇市场的操纵问题。这场讨论的发生让人怀疑“老太太”（Old Lady，这里指英国央行，译者注）知道了什么。英国央行展开了独立调查，并得出结论称，其官员都不清楚市场操纵问题。尽管英国央行有着往好的方面解释自身行为的悠久历史——从银行监管委员会(Board of Banking Supervision)对1995年巴林银行(Barings)丑闻的粉饰性调查，一直到对Libor操纵案的调查——但我们必须接受该行官员全都不知情的结论。即便这是事实，但人们有必要对他们的能力表示怀疑。毕竟，就连不直接涉足市场的记者都能发现那些不当行为。
Market rigging, to judge from the forex affair, continued well after the banking crisis. It kept taking place even after Libor scandal broke. This raises the question whether people at all levels of the forex trading community – traders, managers, regulators and the BoE – will feel adequately chastened by the fines imposed on five banks.
从此次外汇事件判断，市场操纵行为在银行业危机之后依然猖獗。甚至在Libor操纵丑闻爆发之后仍在发生。这让人们怀疑，对5家银行的罚款是否能对外汇交易圈子中各个级别的人（交易员、经理、监管机构和英国央行）产生足够的惩戒作用。
Yet there are finally some signs that the banking industry has got the message. Traders have seen some colleagues marched off for questioning. Some face the threat of criminal charges. Managers are conducting the line-by-line forensic analysis of their business that should have started long ago.
然而，现在终于有一些迹象表明，银行业已经明白过来。交易员看到一些同事被带走询问。一些人面临着刑事指控。经理们正在对业务进行细致的分析审查，他们早就该这么做。
Senior managers in the banks are introducing programmes to change the industry’s culture. Risk and compliance departments are emboldened by the new tone from the top and are being properly intrusive. Regulators now understand that light-touch regulation is no way to run a market and are getting tough in the questions they ask and the deterrents they impose. The Bank of England has belatedly strengthened controls in its dealing area. New rules make it difficult for investment banks to carry out proprietary trading. Compensation practices have been reformed to make it harder for traders to take the money and run.
银行高管正在推出改变银行业文化的计划。高层的新口吻鼓舞了风险管理和合规部门的信心和胆量，他们正在对银行业务进行适度干预。监管机构现在明白，温和监管绝非市场管理之道，因此开始严厉问责并加大威慑。英国央行姗姗来迟地收紧了对其交易领域的控制。新规让投资银行难以开展自营交易。薪酬制度的改革让交易员更难拿钱跑路。
Against this background, it would be surprising if systemic misbehaviour at blue-chip financial institutions persisted but memories are short in financial markets. At the sharp end of the business, a typical career lasts only 20 years. As Christopher Fildes, a doyen of financial journalism, has remarked, moments of maximum danger arise when the last person to have experienced the previous crisis departs. There are no grounds for complacency.
在这种背景下，如果大型金融机构的系统性不当行为仍层出不穷将令人意外，但金融市场很健忘。这一行中最尖端的职业，通常的职业生涯只有20年时间。正如金融新闻业前辈克里斯托弗•法尔兹(Christopher Fildes)所说的那样，当经历过先前危机的最后一人离职时，就是风险最大的时候。现在没有自满的理由。