Senior management accountability has been a priority of global financial services conduct regulators in recent years.

One need only look to a speech on 19 January 2017 by Mark Steward, director of enforcement and market oversight of the UK Financial Conduct Authority (FCA), when he declared that “senior managers ought to be responsible for happens on his or her watch. That’s what shareholders, consumers and the FCA want.” Closer to home, on the same day, Julia Leung, Executive Director, Intermediaries of the Securities and Futures Commission (SFC) delivered a keynote address to the AIMA APAC Annual Forum 2016 in Hong Kong in which she highlighted the SFC’s Manager-in-Charge initiative (MIC Regime) and the SFC’s intention to heighten the accountability of senior management. The SFC considers it important to “foster a sense of genuine responsibility and clear accountability” in senior managers of licensed corporations.