Abstract

Over the last decade, scandals within the UK Financial Service sector have impacted their legitimacy and raised questions whether a compliance culture exists or not. Several institutional changes at the regulatory and normative levels have targeted stakeholders’ concerns regarding compliance culture and led to changes in the legitimation process. This paper attempts to address a gap in the literature by asking the following question: How is the UK financial institutions’ compliance culture shaped by the institutional environment and changing legitimacy claims? Towards achieving this objective, the paper draws on the institutional theory and pays attention to the various configurations of the legitimacy notion (property vs process Suddaby et al. Acad Manag Ann 11(1):451–478; 2017). The paper utilises a longitudinal interpretive design and undertakes a qualitative content analysis of fines issued by the UK regulator and the communicated response of violating firms as well as non-sanctioned firms. Our findings indicate that there is a cyclical ‘evolutionary compliance’ rather than the more widely recognised state of ‘compliance culture’. This culture is fuelled by interchangeable isomorphic forces where the majority of violating firms are seen to issue similar responses to the regulators sanction to maintain their reputation and legitimacy in the market. Notably, legitimacy is now defined within an interactive process between the regulator and firms rather than being static and achieved by ticking the box.

Highlights

  • The UK regulator, the Financial Conduct Authority (FCA),1 has issued discussion papers on compliance culture pre and post the global financial crisis (FSA 2007; FCA 2013, 2016b; PRA 2014), in an attempt to encourage financial institutions to adhere with norms of compliance culture

  • We argue that the modifications in the regulatory approach have influenced the compliance culture, and rendered having a stable compliance culture rather unachievable

  • The emphasis here is on exploring how the UK financial institutions’ compliance culture could be influenced by their interaction with the external institutional environment and in particular, the coercive, normative and mimetic isomorphism processes, and how the legitimation process accompanying the shift in the institutional landscape has been impacted, as discussed

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Summary

Introduction

The UK regulator, the Financial Conduct Authority (FCA), has issued discussion papers on compliance culture pre and post the global financial crisis (FSA 2007; FCA 2013, 2016b; PRA 2014), in an attempt to encourage financial institutions to adhere with norms of compliance culture. Despite these efforts, compliance violations are still evident within the UK financial sector. Compliance can be defined as “conscious obedience to or incorporation of values norms or institutional requirements” (Oliver 1991, p. 152), while culture deals with ‘intraorganizational processes’ (Kondra and Hurst 2009, p. 39),

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