In recent years, fines have been widely used to sanction firms for instances of misconduct [See footnote 1.]. A consequence of the growth in fines and settlements is heightened interest by both firms and authorities in addressing misconduct, especially by holding individuals accountable for their actions. Accountability ["Accountability" occurs where an individual can be held to account for "outcomes" in the areas for which s/he has responsibility.For the purpose of this paper, accountability may take a variety of forms, and the term is not used prescriptively to imply any particular accountability mechanism. At the same time, an employee cannot be described as individually accountable if he or she never faces consequences for misconduct.] can be reinforced by clearly identifying key responsibilities and assigning them to individuals. Such an approach could also support cultural change at firms - for instance, by dispelling notions that fines are the cost of doing business. To help ensure that individuals appreciate and understand the responsibilities to which they have been assigned, an expectation that individuals will adhere to policies that define acceptable and unacceptable behaviours can be embedded in annual performance plans and reviews.

Through their supervisory programmes, national authorities can review the effectiveness of such firm- led approaches - evaluating the possibility that ineffective arrangements might not address misconduct risk. Authorities may use a number of supervisory techniques to promote appropriate standards with respect to conduct, systems and internal controls besides imposing fines or other sanctions on firms. The choice of tools will depend on the legislative arrangements in each jurisdiction that may promote or constrain particular approaches.