For most of the last decade, regulators have encouraged financial institutions to instil a positive compliance culture amongst staff to help ensure that they meet their FinCrime obligations. ‘Tone from the top’ is a phrase that has often been invoked to emphasise the need for business leaders to lead the way for their teams in this.

Yet in the last few years, there have been an increasing number of cases highlighting the failures of senior staff to take FinCrime issues seriously, or support whistleblowing when internal suspicions arose. Some critics have thus suggested that the talk of ‘compliance culture’ from large institutions – well able to afford to pay fines for failure – has in fact been purely rhetorical. Assuming that tougher measures are needed, several jurisdictions have started to bring criminal charges against financial institutions, and sometimes members of staff, in egregious money laundering cases.

In this session, the panel will explore the key issues around the ongoing cultural challenges for the financial service sector. Is it possible to have a positive compliance culture in a commercial institution, or are the incentives faced by staff – senior or otherwise – too contradictory to make that realistic? And if it is feasible, are regulation and relentlessly tougher enforcement measures the right way to achieve it.


• Oonagh van den Berg, CEO & Founder and Managing Director, RAW Compliance and Virtual Risk Solutions


• Eric Young, CEO – Young Enterprises LLC and former CCO – BNP Paribas Americas, Young Enterprises LLC

• Anna Romberg, EVP Legal, Compliance & Governance and Co-Founder Nordic Business Ethics, Getinge AB

• Wies Wagenaar, Head of Compliance: Conduct & Ethics, ABN Amro Bank N.V

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