Global Trustee and Fiduciary Services News and Views Issue 50

Prime, Futures and Securities Services | Culture and Conduct 32 While regulatory approaches have differed from one jurisdiction to the next, one trend that continues to gain increasing traction from national competent authorities is that the issue of continuing poor culture and conduct is being directly linked to the implementation of personal accountability regimes. This is most prominent in the UK, where the Senior Managers and Certification Regime (SM&CR), which was rolled out to banks, credit institutions and insurers in March 2016, will be CULTURE, CONDUCT AND THE RISE OF PERSONAL ACCOUNTABILITY The impact and importance of good culture and conduct within financial services firms is a topic that regulators, both at national and at supranational levels, have grappled with ever since poor culture and conduct were identified as one of the primary drivers behind the global financial crisis of 2007-08. extended to all UK-regulated firms, including asset managers, in December 2019. Further examples can be seen in the introduction of the Manger-in-Charge (MIC) regime in Hong Kong as well as ongoing developments in Australia, Singapore, and Ireland. Before looking at some of these developments in more depth, it’s worth looking at the work of the Financial Stability Board (FSB). In November 2015 the FSB published its progress report on “Measures to reduce misconduct risk.” 1 CULTURE MAY NOT BE EASILY MEASURABLE BUT IT IS MANAGEABLE.