Myriad studies of the causes of the global financial crisis suggested conduct risk failures were major contributors. This led to a call to action, championed by regulators globally, for the financial services industry to take immediate steps to improve its management of conduct risk.

Yet, 10 years after the end of the financial crisis, little seems to have changed, as evidenced by scandals in the last five years. Clearly, massive fines paid by financial institutions since the financial crisis appear to have had limited deterrent effect. In this white paper, we analyze the root causes of conduct risk failures, focusing on five specific but interconnected areas.