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The New Normal: Conduct Risk & Personal Accountability

On April 30th, 2020, Starling released its 3rd annual Compendium, a report on global regulatory activities aimed at promoting improved culture and conduct in the banking sector. The series of reports has traced the evolution in thought regarding the supervision and governance of conduct risk among bank regulators and industry leaders, worldwide. As in previous years, clear trends have emerged, as reflected in the Key Takeaways found in this year’s report:

  • CEO turnover – Misconduct was a principal driver of CEO turnover in the last year, which saw far higher than usual CEO churn. 
  • Personal liability – The last year has seen a continued emphasis on individual accountability and personal liability schemes in several jurisdictions.
  • Anticipating outcomes – Regulatory efforts around culture and conduct risk have become grounded in an overt concern for customer outcomes.


Culture and conduct management challenges were prominent in many industries over the last year, including the banking sector.  As a result, RegTech firms have begun to bring governance tools to market, and some bank regulators now actively promote the trialing of such tools among the firms they oversee.  Heightened regulatory sensitivity to culture and conduct risk implies a need to explore new tools and approaches to risk identification, assessment, and mitigation. 

To access a  full copy of Starling’s Compendium, click here.  Last year, Starling and Regulation Asia shared findings from earlier issues of Starling’s report – covering the UK’s leadership role in driving the global supervisory agenda around conduct and culture and post-Royal Commission developments in Australia, to Hong Kong’s ecosystem approach and Singapore’s push to addressing culture and conduct issues.