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Individual accountability and the key considerations

20 July 2020
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A comparative overview of accountability regimes across three global regions

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In the years following the 2008 financial crisis, financial services regulators in many jurisdictions have increased their scrutiny of individuals carrying out regulated functions. 
 
Regulators have either introduced new or enhanced measures with the aim of driving higher standards of conduct. It has therefore never been more important for firms to understand the extent of the regulatory regimes to which they and their employees are subject.

In that context, we set out a comparative overview of the accountability regimes in nine jurisdictions. For each jurisdiction, you will find an overview of the key aspects of the relevant regime, and practical commentary drawing on our widespread experience. We cover:

  • The Senior Managers and Certification Regime (SMCR) in the UK
  • The Banking Executive and Accountability Regime (BEAR) in Australia
  • The Individual Accountability and Conduct Guidelines (IACG) due to be implemented in Singapore
  • The Senior Executive Accountability Regime (SEAR) due to be implemented in the Republic of Ireland
  • The applicable legislation in Germany, as no unified individual accountability regime is in force
  • The regime implemented via the Italian Financial Intermediaries Act (TUF) and the Italian Banking Act (TUB) in Italy
  • The applicable legislation in Spain, as no unified individual accountability regime is in force
  • The regimes enforced by the Polish Financial Supervision Authority (PFSA) and the President of the Office of Competition and Consumer Protection (OCCP) in Poland 
  • The three key regimes across jurisdictions in the United Arab Emirates enforced by the Central Bank of the UAE, the Dubai Financial Services Authority (DFSA), and the Financial Services Regulatory Authority (FSRA) in Abu Dhabi.

This report will be of particular interest to international financial services firms, as well as national firms operating in any one or more of the jurisdictions covered. 

If you have any questions, please get in touch with the relevant contact within the report.

Further Updates

The Monetary Authority of Singapore launches its Individual Accountability and Conduct Guidelines
The Monetary Authority of Singapore (MAS) have now confirmed the launch of the Individual Accountability & Conduct Guidelines (IACG) in Singapore, affecting all Singaporean Financial Institutions (FIs). The regulator has given FIs just 12 months to implement the regime from its launch on 10 September 2020. Based upon our experiences of individual accountability regimes globally, this is not a lengthy period for the implementation of an initiative that has far reaching organisational impacts.
Read our article to find out more >

Further Reading