Individual accountability won't transform organizational
culture on its own, but firms could make greater use of a resource
they already have.
In recent years, efforts to change the compliance culture in
firms have been have been greatly impacted by the increased
emphasis on individual accountability. Regulators such as the FCA
have repeatedly – and rightly tried to encourage this change
by stressing the importance and influence of the "tone from
the top" in firms.1
However, without an organizational infrastructure to promote,
coordinate and control efforts to change the culture, , these
efforts are likely to fail.
One reason for this is that, in practice, the driving force
behind individual accountability is the threat of sanctions on
individuals for compliance failures for which they are held
responsible. That threat is still relatively slight in
jurisdictions such as the UK,– notwithstanding of course the
introduction of the SMCR. FCA fines in 2017 totaled
