Navigating senior management accountability in large financial institutions

Two recent enforcement actions in September 2025 against senior executives by the Securities and Futures Commission (SFC) demonstrate the regulator’s approach to management accountability in financial institutions. The SFC has suspended a former responsible officer of an asset management company for 12 months, whilst banning a former responsible officer, Manager-In-Charge of Key Business Line, board member and Head of Pan-Asia Equities of a major international investment bank from re-entering the industry for 5 years. Both cases involved supervisory failures only; neither executive had actual knowledge of or involvement in the underlying misconduct.