Leaders along all Three Lines of Defence are being held personally accountable for misconduct that takes place on their watch. To avoid individual liability, they must identify leading indicators of risk that allow for “upstream” interventions, say Starling’s Stephen Scott and former HSBC Global Head of Operational Risk and ORX Chairman, Mark Cooke.
On 30 April, Starling released its 3rd annual Compendium, a report on global regulatory activities aimed at promoting improved culture and conduct in the banking sector. Based on the report’s findings, last month we published an article describing personal accountability for conduct risk failures as being “the new normal.” Here, we focus on the development of “culture audit” requirements.
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