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Beyond compliance

Financial institutions have begun to address misconduct issues, but resolving them for good requires more than rules and regulations.

By Peter Lacy, David Rodin and David Smith


The world’s biggest banks are missing out on a big opportunity. These institutions could boost their earnings by as much as $500 million a year by reducing their misconduct penalties by just 10 percent.1

That’s no easy feat. Many banks have already made significant investments in their compliance function to ensure that all employees observe applicable laws and regulations, yet their reputations and balance sheets continue to suffer.

Consider traditional compliance approaches, which emphasize rules and systems. Rigorous training, combined with better policing in departments like trading and markets, is expected to root out the few “bad apples” responsible for any wrongdoing.

But our research suggests that these tactics aren’t always enough. Successfully addressing the conduct challenge requires a radically different approach—one that goes beyond compliance. Banking leaders must recognize that good conduct depends on ethics and organizational culture as much as it does on rules and systems.

Going forward, these leaders will need to use both hard and soft skills to make better decisions and achieve ethical outcomes across strategy, structure and systems. First, however, they need to understand what’s gone wrong.

Seeing the full picture

From conversations conducted over many months with bankers, academic experts and industry observers, together with a detailed review of past loss events at client banks (see “Behind our methodology”), we have discovered that ethical lapses often have multiple, interrelated causes. The typical explanations for why they occur are largely myths.

Blaming a few Gordon Gekko types, for instance, certainly fits with the all-too-popular image of bankers pursuing personal advancement at the cost of the greater good. That thinking also aligns with an interventionist regulatory agenda, focused on finding and penalizing wrongdoers. The reality, however, is more complicated.

We have found that rogue traders cause very few incidents.2 Instead, employees’ short-term thinking and poor understanding of how to handle complex opportunities are much more often culprits. And, like most industries, banking tends to follow an unwritten rule: never trade doing business for not doing business. Shareholders, after all, want growth, which few companies would achieve if they didn’t seize opportunities as they arise. Not surprisingly, bankers may feel compelled to focus on getting the deal done fast and worry about the consequences later.

In such a culture, more rigorous rulebooks alone won’t ensure ethical behavior. Day-to-day decision making in banking often deals in gray areas, where the letter of the law provides insufficient guidance. Misguided individuals and mismanaged departments—the usual suspects when scandals occur—may just be following standard rules and practices that simply don’t equip them to make informed, ethical decisions.

Our research also reveals the limitations of aligning compensation with ethical behavior. Quantifiable incentives can motivate people to behave better, but so can encouraging them to feel responsible and accountable for ethical outcomes. Banks have incentivized their employees to deliver on short-term financial goals and rewarded them accordingly. The upshot: An own goal. Shareholder value has been destroyed rather than created because too many banks have neglected their civic franchise as agents of long-term societal prosperity.

Understanding ethical drivers

Once banking leaders recognize the cause of past problems, they need to identify the drivers that will generate better outcomes. That starts with establishing a foundation for appropriate behavior at both the organizational and individual levels. Our research indicates that achieving a suitable ethical outcome requires the presence of three conditions. First, there must be a clearly defined domain of individual or organizational responsibility. Second, the responsible actor must be capable of doing the right thing. Third, that actor must be motivated to do the right thing.

There are, in short, a few key questions for employees to consider.

  • Am I responsible? As a business manager, do I have clearly delineated compliance responsibilities? Am I, as a named individual, held responsible and accountable for ethical issues in business selection?

  • Am I capable? Do I understand the ethical implications of my day-to-day decisions? Do I have the ability to recognize and reasonably respond to gray area issues? Are ethical issues embedded into my training and recognized as a core professional competence?

  • Am I motivated? Do I have the appropriate incentives to do the right thing? Am I recognized and remunerated for making decisions that benefit the organization as a whole? Do the shared norms and culture of my social and professional environment motivate me to do the right thing?

In a well-functioning organization, these drivers form a mutually supportive virtuous circle. In a dysfunctional organization, however, weakness in one of the drivers will precipitate the degradation of the others.

Adopting an Ethical Value Proposition

Banks seeking to build the foundations of future success must broaden their approach beyond a discussion of structures and systems. They must also address fundamental questions of purpose and value creation with an Ethical Value Proposition (EVP).

If properly constructed, an EVP can provide a clear statement of purpose and act as a sophisticated management tool that identifies, quantifies and tracks the societal benefits the bank generates—facilitating global trade, providing access to consumer finance, funding small and medium-sized enterprises and startups—against the risks it creates.

In fact, a commonly shared and articulated EVP can be the cornerstone of a bank’s ethical transformation (see below), helping to secure alignment and buy-in across the organization. By clearly stating the bank’s purpose, it can form the basis of interventions designed to change organizational and individual behaviors.


Leadership on ethics and cultural change may be the single biggest strategic opportunity in today’s banking sector for both the short and long term. No bank has yet seized the initiative. Many still balk at what it would entail: for most, a reexamination of the organization as a whole and a reimagining of its purpose and potential. But the rewards of taking action—driving the necessary cultural transformation across strategy, structures and systems—promise to be legion. Focusing on ethical outcomes will limit regulatory fines and associated legal costs, saving banks hundreds of millions of dollars.

Banking leaders, investors and regulators are all beginning to question the wisdom of existing solutions to the ethics challenge. By harnessing new tools and methodologies, banks could transform their approach and restore their own—and the market’s—confidence in the sector’s ability to build a cohesive culture committed to sustainable, long-term value creation.

1 CCP Research Foundation, "Conduct Costs"; Accenture and Principia analysis
2 Accenture and Principia analysis​

Behind Our Methodology


Recognizing the scale of the ethical challenge facing our clients, we have built an unprecedented collaboration. It combines Accenture Strategy’s deep experience in banking and culture change with the innovative research and practical expertise of boutique consultancy Principia Advisory.

Together, we have developed unique insights that can help banks better understand where their ethical problems lie and how they can bring about a transformation in both ethics and culture. Our approach is informed by a proprietary model that banks can use to identify nine key ethical drivers. This has been developed from the latest academic research coupled with discussions with banking leaders. These drivers guide the creation of an Ethical Value Proposition—the foundation for interventions that can support a holistic approach to ethics, not simply in compliance and HR but across all business functions.*

*Both the Ethical Drivers Model and Ethical Value Proposition are proprietary tools of Principia Advisory SARL.

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Peter Lacy

Peter Lacy

Lacy is global managing director for Sustainability Services within Accenture Strategy. He is a world authority on sustainability in areas such as circular economy, stakeholder management and trust issues. He is based in London.

David Rodin

David Rodin

Rodin is one of the world's foremost authorities on organizational ethics. He is the founder of Principia Advisory and a senior research fellow at the University of Oxford. He is based in Geneva.

David Smith

David Smith

Smith is senior managing director for Talent & Organization within Accenture Strategy. He focuses on helping organizations increase the value of their human capital, while also dramatically improving the performance of their enterprises. He is based in Hartford, Connecticut.