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Accountability Regimes: Will they succeed in changing behaviour and culture in banking?

  • United Kingdom
  • ESG
  • Financial services disputes and investigations
  • Litigation and dispute management


The Senior Managers and Certification Regime (SMCR) has been in place in the UK since 2016. It has provided a model for the subsequent introduction of new individual accountability regimes in Hong Kong, Australia and Singapore together with anticipated new individual accountability regimes in Ireland and Malaysia.

The SMCR was created with the aim of improving culture, governance and accountability within financial services firms. But how successful are the SMCR and other similar new individual accountability regimes (IARs) likely to be?

It is too early, at this stage of the implementation of these new regimes, to reach any definitive conclusions on this question. However, Ciaran Walker, Consultant at Eversheds Sutherland, has written an article for the prestigious annual Starling Compendium (Compendium) on “Culture & Conduct Risk in the Banking Sector” which addresses this question.

The article looks at the key features of the IARs, whether they are likely to be successful in improving behaviour and culture, how “success” can be measured and what more needs to be done.

The Compendium is a must-read for all interested in understanding and addressing issues of culture and conduct risk in financial services. This year’s contributors to the Compendium include leading regulators, academics, senior executives in global firms and other thought leaders.

Ciaran’s article follows-on from research in his recent co-authored book, “New accountability in financial services: Changing individual behaviour and culture” (2022).

The Compendium is available to download for free. Please visit Starling Compendium on “Culture & Conduct Risk in the Banking Sector to download your copy.

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