Behavioral risk management in banking is most typically an exercise in applied hindsight: we investigate misconduct only after it is discovered to have taken place, and then revise rules and procedures to aim at known past problems, rather than targeting potential future troubles.
This ‘detect & correct’ mindset has resulted in of billions of dollars in punitive fines across the industry worldwide over the last decade. Estimates put the figure at some $700 billion—and this, despite the tens of billions that firms have invested annually in their governance, risk, and compliance control infrastructures during that same time frame. What is to be done?
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