The FSB surveyed its member jurisdictions to gather further information concerning national authorities’ experiences in implementing individual responsibility and accountability frameworks (including issues that may arise in group structures). The survey provided insights into the outcomes authorities seek to achieve from increasing individual responsibility and accountability and the possible routes to achieving those objectives, and the potential benefits and challenges associated with various approaches.

1. Identifying roles and responsibilities

Many jurisdictions indicated that they have formal statutory authority as it relates to designating responsibilities for senior individuals and holding individuals accountable. The UK has an explicit statutory and regulatory authority for establishing a list of key senior manager roles and promoting individual accountability through responsibility mapping. Meanwhile, Singapore is currently studying possible measures to augment their existing framework through linking roles and responsibilities to accountability. Supervisory and regulatory expectations are in place with respect to roles and responsibilities in several jurisdictions, largely pertaining to the roles and responsibility of the board and senior management. However, several jurisdictions also extend deeper into the senior management layer within the firms, such as the heads of the control functions, the heads of the businesses, or staff levels.

Some jurisdictions allow for some form of dual responsibility for key functions; however this is usually dependent upon the size and complexity of the firm and/or limited to some control function positions (i.e. not including internal audit). Meanwhile, other jurisdictions do not allow for dual responsibility primarily due to concerns over conflicts of interests.