Poor Culture Leads To Poor Conduct In Banks
Introduction
Culture is defined as a system of values and norms that help shape the mindsets within an institution.[1] Individuals can build stronger relationships and more effective communication within the banking sector by recognising and respecting cultural norms and values. Whereas conduct in relation to banking is a set of guidelines to maintain an acceptable level of behaviour and is implemented to ensure that banks operate in a safe and fair manner, it is equally important to maintain the integrity of the banking system.[2] For banks to establish trust and make a positive reputation, it is crucial to prioritise values that contribute to creating trust. Culture plays a critical role and can both be a key driver and a potential mitigant of conduct risk. [3] The Financial Conduct Authority (FCA)[4] encourages firms and senior management to prioritise their conduct and culture, implementing exemplary practises throughout the banking organisation.[5] Bankers have acknowledged that issues like misaligned incentives, poor regulation, inadequate supervision, and poor leadership are some of the causes that have led to poor culture within the banking system.[6]
The main discussion of the paper is whether poor culture is one of the key factors that leads to poor conduct in banks within the global market. Within this essay, elements of compliance with global markets, such as Senior Management Regime (SMR)[7], Global Financial Crisis (GFC), individual accountability, and immediate financial gain, will be discussed in context with culture and conduct to demonstrate this argument further. The first section of this paper will explore the concept of culture and conduct as well as understand the importance of both terms in the context of banking. Secondly, the paper will discuss how the conduct of banks is impacted due to the culture of greed and immediate financial gain that can have detrimental effects and could be a reason for poor cultural practices within the banking sector, resulting in poor conduct. The final section of this paper will examine the banking reforms and regulations that can help develop a culture within the banking sector in the UK and other jurisdictions such as European Union (EU), United States (US) and Singapore. While there are no easy solutions, it is clear that changes are needed to create a more positive banking culture. The author of this paper will conclude that poor culture is the crucial reason for poor conduct, and it is essential to consider the impact that culture can have on the behaviour of individuals and organisations within the banking industry. This could ultimately affect the stability and effectiveness of the banking system, and banks need to focus on developing a solid culture and conduct within the banking sector.
Section One
Concept of Culture and Conduct in Relation to Banking
The first section of this paper will explore the importance of culture and conduct as well as looking into the culture and conduct risk within the banking sector. Before discussing this matter, it is imperative to define culture and conduct. Culture in the banking context is the way individuals in an organisation behave, which affects the organisation’s day-to-day practices and interaction with customers and other market participants.[8] Culture can also determine a banking firm's long-term success and sustainability. The Global Financial Crisis (GFC) of 2008 brought to light various unhealthy practices such as. money laundering, mis-selling policymakers, creating a housing bubble which affected the banking culture.[9] Macartney highlights that the banking culture has become highly restricted as every email is scanned and scrutinised, employees are monitored for behaviour patterns, and criminal penalties have been introduced for misconduct.[10]
On the other hand, conduct in banking is related to the code of conduct set to maintain a standard of acceptable behaviour.[11] The Global Financial Crisis (GFC) of 2008 highlighted that poor banking conduct is one of the biggest material risks that has led to loss of shareholder value with hundreds of dollars of fines to date which continue to grow.[12] Therefore, the Global Financial Crisis (GFC) of 2008 has had a significant impact on the culture and conduct; the crisis eroded the trust of banking and financial institutions leading to significant changes in attitudes and behaviours towards the banking system.[13] As a result, the shift in perception has resulted in a greater focus on transparency and accountability in the financial industry and a heightened sense of caution when investing and making financial decisions.
Importance of Culture and Conduct Risk in Relation to Banking
It is essential to understand the meaning of culture and its link to conduct within the banking sector as well as how risk culture affects the conduct of banks. One of the key reasons culture within the banking sector is important is because it serves as a potential mechanism to build a strong reputation, retain trust, and maintain the business's performance. Furthermore, culture can dictate an organisation's decisions and priorities and how employees interact with each other and their clients.[14] Pascalis highlights that poor conduct is usually because of poor culture in the banking and financial sector.[15] Poor conduct in practice is down to poor leadership and because reward policies are more focused on increasing the risk of selling or cross-selling unsuitable products and therefore, poor culture is seen as a key contributing factor of conduct risk.[16] The culture of banks is essential as it helps shape safety, and banks with poorer cultures are substantially more at risk.[17]
The term risk culture in banking is referred to a set of norms, attitudes and behaviours that helps to shape the day-to-day decisions made by management and employees, the decisions made do have an impact on the risks that they take.[18] The risk of poor culture is based on uncertainty and the potential for failure that is caused by human behaviour.[19] The Global Financial Crisis of 2008 is an excellent example of how human behaviour in banks created a high risk culture by mis-selling financial products, which led to various consequences. Furthermore, commentators have argued that the Global Financial Crisis initiated the awareness of poor culture and the reason why poor conduct has become a key issue in the banking sector.[20] The Financial Conduct Authority (FCA)[21] is the primary conduct regulator for the banking sector, which focuses on how financial institutions' actions impact consumers. Academics argue that a clear leadership of strategic and operational requirements from management's behavioural expectations enables good culture and helps to facilitate good conduct.[22] Based on the financial crisis, it is evident that good culture is required for good conduct within the banking sector. Therefore embedding a good cultural structure will help return the trust in banking amongst all stakeholders.[23] Banking culture has become a crucial topic for banking regulators. McCalman further states that culture delivers behaviour values that help shape conduct and is an asset for banks.[24] As a result, by promoting a positive culture, banks can foster a sense of accountability and transparency that benefits everyone involved. However, in recent times this concept of good culture and good conduct within the banking sector has been decreasing due to the prioritisation of immediate financial gain, which will be discussed below.
Section Two
Impact on Conduct of Banks due to the Culture of Immediate Financial Gain
The second section of this paper will discuss the prioritisation of immediate financial gain within the banking sector, ultimately leading to poor cultural practices, resulting in poor conduct, and damaging the industry’s reputation. A cultural framework is highly relevant to a firm’s performance, and banks must consider the long-term effect of their actions and prioritise cultural behaviour to maintain the trust of their clients and stakeholders.[25] Furthermore, based on recent studies, academics, Courtois, and Gendron have examined the process where banks, organisations and individuals have embraced the culture of corruption, and fraud has become normalised.[26] Some academics have expressed concerns about the financial institutions in regards with remuneration practices which had encouraged high-risk taking.[27] In addition, to the financial crisis, a new scandal hit the industry known as the LIBOR scandal which was a highly public scheme and several big banking institutions had colluded to manipulate the LIBOR.[28] Furthermore, banks paid more than £200 billion in fines and damages worldwide because of poor culture and conduct due to the rise in the hierarchy of critical financial risks when investing in banks.[29] As a result, the financial crisis and the LIBOR scandal damaged the public’s trust in banking institutions. The financial scandals are a result of the “greed culture“ of gaining high bonuses, which leads to the poor conduct such as casino banking and high-risk banking resulting in the huge losses for banks leading to a financial crisis. It also results in massive cost, for example misconduct through poor culture has cost UK banks £26.5 billion [30] Greed within the banking culture has resulted in making banks more likely be dishonest and more prioritised towards financial gain.[31] However, it is important to consider when maintaining a culture within the banks that culture is intangible and is, therefore, often overlooked.[32] Sceptics view that banks are more prioritised on maximising profit rather than focusing improving culture and conduct and providing customer value.[33]Therefore, it is shown that in some situations, financial gain and profitability are prioritised over the value of cultural practices within the banking industry.
Moreover, it is essential to analyse why poor culture exists in banks in this section. To further elaborate, Pascalis explains that the concept of conduct risk was due to high-profile cases of misbehaviour that have recently affected the financial services sector globally, particularly the banking sector.[34] One of the biggest crisis within the banking sector was the Global Financial Crisis (GFC) of 2008 that greatly impacted individuals and institutions worldwide as banks offered highly competitive and unprofitable housing markets loans.[35] For instance, lending practices of financial products, the manipulation of interbank proposed rates, tax evasion and violation of anti-money laundering rules determined widespread poor conduct within banks.[36] Following the financial crisis of 2008, the UK banks paid £71 billion in legal fees, compensation and additional fines for poor misconduct.[37] Banking and financial institutions were liable for the damages to their customers because of their loss relating to fines or other financial penalties imposed by regulatory authorities.[38] As a result, bad behaviour is stigmatised as unhealthy and poor culture in banking and financial sectors and is considered the first pillar of the conduct risk concept.[39]
The aim of an immediate financial gain mentality can have adverse effects on the culture within the banking industry, leading to negative practices and poor conduct. Montenegro further states that researchers found that bankers are likely to lie and cheat and wonders whether today’s banking culture promotes ‘fraudulent and unethical behaviours” and a perspective of acquiring quick financial gain.[40] The view demonstrates how the banking culture is focused on immediate financial gain and banks making a profit and therefore has taken over the ethical and moral considerations of individuals working in the banking sector. The Dear CEO letter published by the FCA aimed at wholesale market broking firms, identified culture and mindset as one of the key drivers of harm to focus on and which highlighted the risk of market abuse and financial crimes that could be committed or facilitated by the brokers for higher financial gains.[41] Enria further states that achieving a permanent mindset change is still challenging within the banking sector despite improving culture and conduct.[42] Therefore, it is clear that the banks need to pursue a cultural mindset to restore trust in the banking system inevitably.
Final Section
Changes in Regulation to Improve Culture and Conduct in Banks - UK
The paper's last section will delve into potential reforms to tackle the poor culture in the banking sector. There are no quick solutions; however, better culture should be implemented to foster a more optimistic banking culture. Since the Global Financial Crisis (GFC) of 2008, new and improved regulations within the banking institution have been introduced to be able to change the mindset of culture within the sector. For instance, the FCA[43] and PRA[44] created an individual accountability to make everyone in the banking institutions accountable for any misconduct.[45] One of the FCA and PRA proposals was the Senior Management Regime (SMR) which is consolidated in the Financial Services and Markets Act 2000 to implement changes to transform banks' culture and senior bank managers' conduct through individual accountability and sanctions for non-compliance.[46] The Senior Management Regime (SMR) 2016 became effective for banks, including UK branches of overseas banks, credit unions and building societies; it also included board members, anyone on the executive committee and certain specific individuals such as Internal Auditors and the most senior leaders who are personally held accountable.[47] Another proposal suggested by the FCA and PRA is the certification rules which ensure that particular individuals who can impact the bank's reputation or its customers are fit and proper to perform their roles. Davidson states that the failures of banks from the GFC 2008 and the scandals is the reason as to why the Senior Managers Regime is a vital way to assist banks in shaping their own culture and provide regulators with the powers to conduct supervisory management and function when required.[48] As a result, the regime allows leaders and management of banks to structure a good culture to enhance the reputation and trust of banking and financial firms.[49] However, one of the main concerns with the Senior Manager Regime is a need for more clarity on who is responsible for culture and how the right culture is embedded and measured within a firm, which has led to the introduction of more detailed board minutes within the banking institution.[50]
Other Jurisdictions
Similarly, within the EU, the European Securities and Markets Authority 2011 contributes to safeguarding the stability of the EU's banking and financial system to enhance investor protection and promote stable financial markets.[51] The ESMA will continue to encourage the creation of a common supervisory culture regarding non-financial reporting.[52] ESMA key objectives are to assess the risk to investors, markets and financial stability, as well as completing a single rule book for EU financial markets, promoting supervisory convergence and directly supervising specific financial entities. Furthermore, regulators from Banco Santander state that to sustain culture within the sector, the bank has had to work hard, and Santander has created an extensive culture management regime to help measure culture.[53] Gonzalez argues that reforming the organisation's culture is equally essential when digitalising the bank's operations.[54] Therefore, it's necessary for the bank to not only focus on implementing digital transformation while also adopting a new mindset and culture.
In the US, the principal securities regulatory body, the Financial Industry Regulatory Authority (FINRA)[55] is the largest non-governmental regulator in the country and plays a crucial role in ensuring fair and transparent practices in the securities firms doing business in the US.[56] One of the new focuses for FINRA is on banking firm culture and demonstrates that the interest in reforming culture came from the financial crisis, such as the manipulation of LIBOR[57]and foreign-exchange rates.[58] Musalem highlights that culture is as essential as liquidity and capital and requires constant attention; regulators must impose strict rules while finding ways to reform the banking culture to restore trust within the banks.[59] Equally, the Monetary Authority of Singapore (MAS)[60], Singapore’s central bank and integrated financial regulator, fosters well-functioning financial markets and is established to promote culture and strengthen the standards of conduct within banks. Therefore, banking regulations across jurisdictions such as the, UK EU, US and Singapore have acknowledged the need to build a solid culture to shape the conduct or behaviour of the banking and financial sectors.[61]
However, it is essential to note that the approach and mindset from a business perspective about 'the problem' are distinct from legal solutions. The question to consider is how far legal remedies and law reforms could transform the culture of banks. Reforming the law represents a change in conduct. More research is required to examine how regulations affect leadership and, ultimately, shaping the organisation's culture is critical to finding the practical solution.[62] As a result, it is evident that an increasing number of banking regulators around the world have realised the critical significance of culture and how it can lead to good conduct and slowly rebuild trust and assurance among customers, employees, shareholders, and the markets [63]
Conclusion
In conclusion, the author of this paper to agrees with the primary debate that poor culture in banks does lead to poor conduct due to many factors, such as poor leadership, greed, and risk culture, lesser regulation, and weak corporate governance. Good Culture is essential in the banking industry because it establishes trust and creates an image that banks recognise cultural norms and values. As emphasised throughout this essay, culture is crucial to the success of the banking institution. The variety of academic viewpoints highlights that culture has become a central issue within the banking and financial institution. The Global Financial Crisis (GFC) of 2008 highlighted the impact of poor culture and misconduct within the banking sector. Therefore, ever since this financial crisis, regulators worldwide have brought on regulations to improve culture and conduct and change the mindset within the banking system. For instance, the Financial Conduct Authority (FCA) and Prudential Regulation Authority (PRA) introduced an Individual Accountability Regulation, which develops greater personal accountability in banks and the financial sector.
Regulations in other jurisdictions have focused on maintaining a good culture and conduct in banks. For instance, the EU introduced a European Securities and Markets Authority 2011, the US implemented Financial Industry Regulatory Authority and Singapore also introduced the Monetary Authority of Singapore which helps to safeguard by promoting stable financial markets and by contributing, can create a more secure and trustworthy financial environment. As a result, the reforms of legislation and regulations are implemented to support a healthy financial sector through improving better and enhanced culture practices which ultimately would lead to a more positive conduct within the banks. It is important to acknowledge that law reform represents a change in conduct; however, laws or regulations do not change culture; people do. Overall, poor culture does lead to poor culture and individuals and banks’ mindset will need to be changed to be able to promote good culture creating a positive conduct in the banking sector.
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Footnotes
[1]Philip Lee, 'Banking Culture - A Dirty Word?' (2018)<https://www.lexology.com/library/detail.aspx?g=25eecc28-9ba5-4b81-b471-2c125237803f>accessed 10th April 2023.
[2]Oliver Wyman, 'Banking Conduct And Culture – The Need To Go Deeper'
(2023)<https://www.oliverwyman.com/our-expertise/insights/2019/feb/banking-conduct-and-culture.html>accessed 10th April 2023.
[3]Peter Andrews, 'Culture in UK Banking' (2016)<https://www.fca.org.uk/insight/culture-uk-banking>accessed 10th April 2023.
[4]FCA, 'The Financial Conduct Authority'<https://www.fca.org.uk/>accessed 10th April 2023.
[5]Jonathan Davidson, 'Getting culture and conduct right - the role of the regulator' (2016)
<https://www.fca.org.uk/news/speeches/getting-culture-and-conduct-right-role-regulator>accessed 10th April 2023.
[6]Deloitte, 'Deloitte – Culture in Banking – Under The Microscope'
(2013)<https://www2.deloitte.com/content/dam/Deloitte/uk/Documents/financial-services/deloitte-uk-culture-in-banking.pdf>accessed 10th April 2023.
[7]Senior Management Regime 2016 (SMR 2016).
[8]FCA, 'Culture in Banking'<https://www.fca.org.uk/publication/foi/foi4350-information-provided.pdf>accessed 3rd May 2023.
[9]ibid.
[10]Huw Macartney, 'What’s wrong with bank culture?'
(2019)<https://blogs.lse.ac.uk/businessreview/2019/10/09/whats-wrong-with-bank-culture/>3rd May 2023.
[11]Oliver Wyman, 'Banking Conduct And Culture – The Need To Go Deeper'
(2023)<https://www.oliverwyman.com/our-expertise/insights/2019/feb/banking-conduct-and-culture.html>accessed 10th April 2023.
[12]ibid.
[13]ibid.
[14]Anjli Raval, Stephen Morris, and James Fontanella-Khan, 'Culture clash: the challenge of uniting fierce rivals UBS and Credit Suisse' (2023)<https://www.ft.com/content/12d8b5c0-12c7-4769-8f03-e68424abe36e>accessed 10th April 2023.
[15]Francesco De Pascalis, 'Conduct Risk: Meaning, Interpretation and Dissension' (2019) 30(6) European Business Law Review 954.
[16]Francesco De Pascalis, 'Conduct Risk: Meaning, Interpretation and Dissension' (2019) 30(6) European Business Law Review 954.
[17]Joel Suss, David Bholat, Alex Gillespie, and Tom Reader, 'Organisational Culture and Bank Risk' (2021)<https://www.bankofengland.co.uk/-/media/boe/files/working-paper/2021/organisational-culture-and-bank-risk.pdf>accessed 15th April 2023.
[18]European Central Bank, 'Strong Risk Culture — Sound Banks'(2023)
<https://www.bankingsupervision.europa.eu/press/publications/newsletter/2023/html/ssm.nl230215_3.en.html#:~:text=Risk%20culture%20is%20a%20set,on%20the%20risks%20they%20take.>accessed 3rd of May 2023.
[19]'The culture and conduct risk - Series 1'<https://www.effectivegovernance.com.au/page/knowledge-centre/news-articles/the-culture-and-conduct-risk-%E2%80%94-series-1>
accessed 3rd May 2023.
[20]Joel Suss, David Bholat, Alex Gillespie, and Tom Reader, 'Organisational Culture and Bank Risk' (2021)<https://www.bankofengland.co.uk/-/media/boe/files/working-paper/2021/organisational-culture-and-bank-risk.pdf>accessed 15th April 2023.
[21]'Financial Conduct Authority'<https://www.fca.org.uk/>accessed 11th April 2023.
[22]David Kenmir and David Hislop, 'FCA conduct regulation' (2013) 110 Compliance Officer Bulletin 1-27.
[23]'Banking Conduct and Culture A Permanent Mindset Change' (2018)
<https://group30.org/images/uploads/publications/aaG30_Culture2018.pdf>accessed 10th April 2023.
[24]Anjan Thakor, 'Corporate Culture in Banking: Why It Matters' (2016)<https://blogs.law.ox.ac.uk/business-law-blog/blog/2016/10/corporate-culture-banking-why-it-matters>accessed 13th April 2023; Professor James McCalman, Dr Angus Young and Dr Raymond Chan, 'Kingdom: strengthening legal accountability or just better leadership?' (2017) 32(6) Journal of International Banking Law and Regulation 261-268.
[25]Yiwei Fanga, Franco Fiordelisib, Iftekhar Hasand, Woon Sau Leunge and Gabriel Wongf, 'Corporate Culture and Firm Value: Evidence From Crisis' (2023) 146 Journal of Banking & Finance 06710.
[26]Oussama Ouriemmi, Benoît Gérard 'Control dynamics in rogue trading: Sovereignty and exception-to-the-rule attitudes in the contemporary financial sphere' (2023) 91 Critical Perspectives on Accounting 102414; C Courtois, Y Gendron, 'The “normalisation” of deviance: A case study on the process underlying the adoption of deviant behaviour Auditing:' (2017) 36 A Journal of Practice & Theory 15-43.
[27]Jake Green, Lorraine Johnston and Bisola Williams, 'Corporate Governance in Financial Institutions' (2017) 146 Compliance Officer Bulletin 1-30.
[28]London Interbank Offered Rate (LIBOR) Scandal.
[29]Paul Cox and Diandra Soobiah, 'Evidence on post-financial crisis corporate culture in UK listed banks' (2018) 19 J Banking Reg 149.
[30]ibid.
[31]Robert Montenegro, 'Study: Banking Culture Implicitly Promotes Greed, Dishonesty, and Cheating' (2014) <https://bigthink.com/technology-innovation/study-banking-culture-implicitly-promotes-greed-dishonesty-and-cheating/>accessed 18th April 2023.
[32]Paul Cox and Diandra Soobiah, 'Evidence on post-financial crisis corporate culture in UK listed banks' (2018) 19 J Banking Regulation 149.
[33]Paul Cox and Diandra Soobiah, 'Evidence on post-financial crisis corporate culture in UK listed banks' (2018) 19 J Banking Regulation 149.
[34]Francesco De Pascalis, 'Conduct Risk: Meaning, Interpretation and Dissension' (2019) 30(6) European Business Law Review 954.
[35]Andrew Loo, '2008-2009 Global Financial Crisis' (2023)
<https://corporatefinanceinstitute.com/resources/economics/2008-2009-global-financial-crisis/#:~:text=It%20began%20with%20the%20housing,and%20require%20a%20governmental%20bailout.>accessed 18th April 2023.
[36]Francesco De Pascalis, 'Conduct Risk: Meaning, Interpretation and Dissension' (2019) 30(6) European Business Law Review 954.
[37]Jamie Nimmo, ‘£71 Billion...The Cost of Our Banks’ Misconduct: our Investigation Reveals the Fines, Fees and Compensation Since 2008 Crisis’(2018)
<https://www.thisismoney.co.uk/money/markets/article-6097965/71-billion-cost-banks-misconduct.html>accessed 15th April 2023.
[38]Andrea Resti, ‘Fines for Misconduct in the Banking Sector-What is the Situation on the EU? European Parliament’ (2017)
<http://www.europarl.europa.eu/RegData/etudes/IDAN/2017/587400/IPOL_IDA(2017)587400_EN.pdf> accessed 15th April 2023.
[39]Francesco De Pascalis, 'Conduct Risk: Meaning, Interpretation and Dissension' (2019) 30(6) European Business Law Review 954.
[40]Robert Montenegro, 'Study: Banking Culture Implicitly Promotes Greed, Dishonesty, and Cheating' (2014) <https://bigthink.com/technology-innovation/study-banking-culture-implicitly-promotes-greed-dishonesty-and-cheating/>accessed 18th April 2023.
[41]FCA, 'Dear CEO letter: Wholesale market broking firms' (2019)
<https://www.fca.org.uk/publication/correspondence/dear-ceo-letter-wholesale-market-broking-firms.pdf>accessed 11th April 2023.
[42]Andrea Enria, 'Just a few bad apples? The importance of culture and governance for good banking' (2019)<https://www.bankingsupervision.europa.eu/press/speeches/date/2019/html/ssm.sp190620~f9149fe258.en.html>accessed 11th April 2023.
[43]Financial Conduct Authority
[44]Prudential Regulation Authority
[45]FCA, 'Prudential Regulation Authority and Financial Conduct Authority consult on proposals to improve responsibility and accountability in the banking sector' (2014)
<https://www.fca.org.uk/news/press-releases/prudential-regulation-authority-and-financial-conduct-authority-consult-proposals-improve>accessed 12th April 2023.
[46]Professor James McCalman, Dr Angus Young and Dr Raymond Chan, 'Regulating the culture of banks in the United Kingdom: strengthening legal accountability or just better leadership?' (2017) 32 Journal of International Banking Law & Regulation 261 - 268; Clive Adamson, 'The Importance of Culture in Driving Behaviours of Firms and How The FCA Will Assess This' (2013)
[47]Professor James McCalman, Dr Angus Young and Dr Raymond Chan, 'Regulating the culture of banks in the United Kingdom: strengthening legal accountability or just better leadership?' (2017) 32 Journal of International Banking Law & Regulation 261 - 268; Clive Adamson, 'The Importance of Culture in Driving Behaviours of Firms and How The FCA Will Assess This' (2013)
[48]Jonathan Davidson, 'Getting culture and conduct right - the role of the regulator' (2016)
<https://www.fca.org.uk/news/speeches/getting-culture-and-conduct-right-role-regulator>
accessed 16th April 2023.
[49]ibid.
[50]Eleanore Hickman, 'Is the Senior Managers and Certification Regime Changing Banking for Good?' (2021) 85(6) The Modern Law Review 1443.
[51]European Securities and Markets Authority, 'Annual Work Programme'
(2020)<https://www.esma.europa.eu/sites/default/files/library/esma20-95-1132_2020_annual_work_programme.pdf>accessed 30th April 2023.
[52]ibid.
[53]'Culture & Conduct Risk in the Banking Sector' (2021)<https://www.finsia.com/sites/default/files/2021-05/Starling%20Compendium%20%2817.MAY_.21%29.pdf>accessed 1st May 2023.
[54]'ibid.
[55]Financial Industry Regulatory Authority.
[56]Financial Industry Regulatory Authority 2007.
[57] The LIBOR Scandal was where bankers at several major financial institutions conspired with each other to manipulate the London Interbank Offered Rate (LIBOR) - Jason Fernando, 'What Was the LIBOR Scandal? What Happened and Impacted Companies' (2022)
<https://www.investopedia.com/terms/l/libor-scandal.asp#:~:text=The%20LIBOR%20Scandal%20was%20a,%2C%20lawsuits%2C%20and%20regulatory%20actions.>accessed 5th May 2023.
[58]'NRA Is Concerned About Firm Culture: What Does It Mean?'
<https://www.sidley.com/~/media/publications/law360_finra-is-concerned-about-firm-culture_what-does-it-mean.pdf>accessed 10th May 2023.
[59]ibid.
[60]Monetary Authority of Singapore 1971.
[61]ibid.
[62]Monetary Authority of Singapore, 'Good Culture and Conduct'(2019)
<https://www.mas.gov.sg/who-we-are/annual-reports/annual-report-2019-2020/responsible-and-trusted-financial-centre/good-culture-and-conduct>accessed 12th May 2023.
[63]Jonathan Davidson, 'Getting culture and conduct right - the role of the regulator' (2016)
<https://www.fca.org.uk/news/speeches/getting-culture-and-conduct-right-role-regulator>
accessed 14th May 2023.