IN the aftermath of a number of large-scale financial scandals, regulators in major financial centres have taken steps to implement a specific regime holding senior managers directly accountable for the failings of a financial institution. These regimes include the Senior Managers Regime in the United Kingdom, which has been in force since 2016, and the Manager-in-Charge Regime by the Securities and Futures Commission in Hong Kong which became fully operational in October 2017. In Australia, public consultations are currently being held on the implementation of the proposed Banking Executive Accountability (BEAR) Regime.

The overarching aim of these regimes is to identify specific senior managers in charge of particular business lines in the financial institution at the outset, such that they can be held directly accountable for breaches of laws in relation to that business line.

This means that it will be difficult for senior managers to say, "It is not my fault, I didn't know" or "Someone else was taking charge of it". If found guilty of breaching their duties under these regimes, they may be personally liable for a criminal offence, or have their remuneration reviewed and adjusted by the regulators amongst other consequences.