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 (the Manager-in-Charge regime, 2016), Australia (the Banking Executive Accountability Regime, 2018, soon to be replaced by a more extensive Financial Accountability Regime), and Singapore (Guidelines on individual accountability and conduct, 2021), together with anticipated new individual accountability regimes in Ireland and Malaysia.
The SMCR was “created against the backdrop of a clear — and shared — understanding that culture [in financial services] needed to change and a culture of personal responsibility had to be embedded”.1 A key question is: how successful are the SMCR and other similar new individual accountability regimes (IARs) likely to be in their aim of improving behaviours and culture in financial services?
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