It is easy to get into a situation where you, without reflection, try to obey and comply with all regulatory demands. But there is a need to use common sense and adapt the regulatory expectations to your governance model and organisational structure.
An efficient risk management starts with a strong risk culture. The risk culture and the way of managing the risk in all dimensions needs to be understood and accepted by the co-workers and therefore to continuously be explained and promoted by the management team.
Trust is everything for a bank. This means that the bank must have an adequate organisational structure and a clear distribution of roles and responsibilities and segregation of duties to ensure that the operations are governed in a suitable and logical way.
Anyone seems to agree upon the notion you need to walk as you talk. Persons in managerial positions therefore need to behave in accordance with the company values. But proper and relevant leadership is unfortunately more complex than that.
The Board/Supervisory Management sets the tone at the top in the company and has the ultimate responsibility to secure adequate governance and internal control. The Board therefore need to have sufficient insight and understanding of the operational prerequisites and needs.
