The Senior Managers and Certification Regime in Financial Firms: An Organisational Culture Analysis

Journal of Corporate Law Studies 2022

36 Pages Posted: 7 May 2022

See all articles by Keller Anat

Keller Anat

King's College London - The Dickson Poon School of Law

Andreas Kokkinis

University of Birmingham

Date Written: April 4, 2022

Abstract

This article critically interrogates the experience of the implementation and enforcement of the Senior Managers and Certification Regime (SMCR) in light of interdisciplinary literature on organisational culture. We demonstrate that the SMCR brings the promise of enhancing effective regulatory supervision of firm culture, supporting the incipient professionalisation of senior manager functions in the financial sector and discerning tangible aspects of artefacts and behaviours that constitute the external layer of good culture. However, we argue that, apart from the more obvious risk of too little enforcement or enforcement targeted at misconduct in the private sphere, there is a risk that a perception of rigidity in enforcement may lead to the development of a counterproductive culture, especially if firms unduly rely upon tick-box quantitative measurement approaches to culture management, and that sound culture may be simplistically equated to compliance with the SMCR. This necessitates a careful and nuanced approach to supervision.

JEL Classification: K2

Suggested Citation

Anat, Keller and Kokkinis, Andreas, The Senior Managers and Certification Regime in Financial Firms: An Organisational Culture Analysis (April 4, 2022). Journal of Corporate Law Studies 2022, Available at SSRN: https://ssrn.com/abstract=4083001 or http://dx.doi.org/10.2139/ssrn.4083001

Keller Anat (Contact Author)

King's College London - The Dickson Poon School of Law ( email )

Somerset House East Wing
Strand
London, WC2R 2LS
United Kingdom

Andreas Kokkinis

University of Birmingham ( email )

Edgbaston, Birmingham B15 2TT
United Kingdom

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