Today's Sunday Times reports this will be a busy week for the implementation of the Senior Persons Regime - seeking to improve conduct in financial institutions and aimed at CEOs, Chairman and committee chairs. The paper indicates that BOE Governor Carney will request this week names of applicable risk governance professionals as part of the Senior Persons Regime which is due back to the Bank no later than March. Andrew Bailey, Head of the BOE's supervisory division is quoted saying that boards must take collective responsibility for their firm's strategy, risk appetite and ethical behaviour. As noted before, under the Senior Persons Regime, the burden of proof reverses to the governance actor such as a committee chairman to establish they were unaware of dubious behaviour or at least had challenged misconduct. Until now, the burden fell on the regulator to prove systematic shortcomings in governance and conduct. A new charge called reckless misconduct has been labeled which can lead a bank boss to go to jail if found afoul of these rules.
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