The Accountability Advantage: How the most effective institutions navigate regulatory pressure and operational complexity.

Chris Davey, Helen Vowls 6 Aug 2026

image of financial diagram on Chicago office buildings background

Respect the Process, Not the Paperwork

 

Conversations about regulatory remediation often drift towards technology programmes, data platforms and transformation budgets. Across our discussions with various senior banking operations leaders, the focus landed somewhere else. One of the most striking insights was that banks rarely fail because they lack frameworks or tools. They fail because they convince themselves they are in control when they are not.

The organisations that navigate regulatory scrutiny most effectively are the ones willing to confront uncomfortable facts, answer simple questions honestly and create real accountability across the business.

Regulators are asking simpler questions than banks expect

 

One theme which came through repeatedly was that regulatory scrutiny has become more sophisticated, but the questions themselves remain remarkably basic.

Leaders consistently highlighted that the challenge starts with understanding what actually happens in the bank. How many issues occur? Where are the breaks? What risks emerge? If leadership cannot answer those questions with confidence, accountability becomes impossible.

Secondly, the mistake many institutions make is assuming regulators are evaluating the quality of documentation. In reality, they are testing whether the organisation genuinely understands how it operates. Plans are rejected not because they lack volume, but because they are unclear, fragmented or fail to answer the question being asked.

The lesson is straightforward. Respect the regulator, respect the process and assume every statement will be challenged, cross-referenced and evidenced. Firms that treat remediation as a communications exercise eventually find themselves exposed.

Real accountability changes behaviour faster than investment

 

Another observation from the leaders we spoke with was that progress accelerated when senior executives met every week, reviewed risks collectively and were held accountable in front of their peers. The visibility created pressure, but more importantly it created ownership. Leaders had to explain where progress had been made, where it had stalled and what would happen next.

As one senior operations executive reflected, there was little room to hide within these governance forums. Importantly, the objective was not to create pressure for its own sake. The strongest governance environments encouraged openness, early escalation and collective problem-solving. Accountability worked because it clarified ownership and accelerated decision-making, not because it sought to attribute blame.

Many transformation programmes underestimate this point. Governance is often dismissed as bureaucracy. Effective governance is something different. It creates transparency, exposes weak assumptions and forces decisions that would otherwise be deferred. The discipline of visible accountability often achieves more than another layer of programme management.

Data issues are often the symptom of a bigger operating model problem

 

Banks frequently describe consent orders and regulatory findings as data issues.

The experience shared by the senior leaders we spoke with suggests that interpretation is often too narrow.

Poor reporting, inaccurate risk aggregation and inconsistent management information usually reflect deeper structural problems. Many institutions have accumulated layers of products, systems and organisational silos over decades. The result is a fragmented view of risk and performance that becomes visible only when regulators start asking fundamental questions.

The contrast between firms that successfully integrate acquisitions and those that do not is particularly striking. Organisations that fail to connect systems, processes and ownership structures create complexity that eventually surfaces through reporting failures, control weaknesses and regulatory scrutiny.

Data matters, but the underlying challenge is often organisational coherence.

Technology is an enabler, not the answer

 

The conversations challenged a common assumption across financial services, that technology remediation automatically leads to operational improvement.

The leaders we spoke with were of the view that technology is essential, but rarely sufficient. All too often, organisations deploy platforms before fully understanding the operating model they are trying to improve. New tools are introduced while underlying processes remain fragmented. The result is complexity layered on top of complexity.

One observation stood out repeatedly: banks can become very good at implementing technology without thinking through how work flows end-to-end across the organisation. When that happens, downstream teams inherit the consequences of poor upstream decisions. Errors travel through the process, creating operational friction, control challenges and unnecessary cost.

The strongest institutions understand the entire chain. They know where an issue will first appear, where it will surface next and how it can be corrected before it becomes a material problem.

A final thought

 

The strongest message from these conversations was that regulatory success is rarely about producing better paperwork. It is about building organisations that genuinely know how they operate.

Banks that can answer simple questions clearly, connect technology to operating reality and create visible accountability across leadership teams are consistently ahead of those still searching for the next programme, platform or transformation slogan.

Image of Leathwaite employee Chris Davey

Chris Davey

Chris is a consultant in the Technology and Operations practice in London. He executes global searches across various industries but with a focus on insurance, asset/investment managers, private equity, banking, payments and FinTech, helping to place exceptional CIO, CTO and…

See full profile
Image of Leathwaite employee Helen Vowls

Helen Vowls

Based in London, Helen leads Leathwaite’s global operations and supply chain practice placing COOs, operations and operating leads across Europe, North America and Asia. She is also a long established partner within he firm’s global technology and digital practice, advising…

See full profile