Abstract

As global financial institutions try to resolve legacy conduct issues and rebuild trust with clients, recent congressional hearings showing senior banking executives being challenged on systematic misconduct within their banks are a stark reminder that work on organisational culture in the sector is as pressing now as at any point during the banking crisis of the last ten years. If positioned well in the organisation, compliance should be a culture-carrier and be present at those crucial moments when important decisions are being made. Compliance can provide the check and challenge on organisational culture, values and ethics, but this requires compliance professionals to have a very different skill set from the legal and compliance officers of the past. While some of these skills can and should be taught, the dynamic nature of the business in this digitised, disrupted sector means learning is likely to be much more effective if it becomes part of ‘the way we do things around here’.1 The authors share their experience in building the skills and capabilities required for compliance to ensure business is ‘complying with the spirit as well as the letter of prevailing regulation and law’.2 This paper will also explore what is required to advance towards a learning culture where learning and innovation happen organically and spontaneously rather than programmatically.

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