Regulatory Unwrapped: How can firms win the conduct and culture war?

In this episode of Regulatory Unwrapped, experts Britt Johnston, Managing Director, Head of Conduct and Culture, Europe, Natixis, and Rob Mason, Director of Regulatory Intelligence, Global Relay, discuss how firms can stay ahead in the “conduct and culture war”.

From whether the traditional “three lines of defense” model is still relevant to advances in surveillance technology finally closing the voice gap, listen in as the experts explore why the same misconduct is treated differently across firms and borders, and where accountability really lands when things go wrong.

Tune in for answers to big industry questions, including:

1. Is the traditional “three lines of defense” model fit still for purpose?

• Accountability gaps persist across the three lines, with shared risk often meaning diffused accountability —not genuine, shared responsibility.
• Communications monitoring must expand across all lines and wider populations (IT, legal, etc.), but resourcing must keep pace across all three lines, not just the third.

2. Do conduct rules keep failing to change behavior?

• Incentive structures often reward the opposite of what the rules demand. A focus on recognizing good conduct, not just penalizing bad, could shift behavior.
• “Tone from the top” is defined by what’s tolerated, not what’s stated. When leaders face no consequences, it normalizes misconduct down from the top down.

3. Why do different firms and jurisdictions treat the “same” misconduct differently?

• What counts as serious misconduct depends on a firm’s risk appetite, not a universal standard. Cultural differences can make global consistency nearly impossible.
• Expanding non-financial misconduct may prove challenging for non-bank firms, as new populations may push back against unfamiliar compliance expectations.

4. Where does accountability sit?

• Complicity matters, being present and silent raises the question of what consequence should follow for not escalating.
• Firms not monitoring across all channels can lack visibility into how employees engage with one another; misconduct is missed when monitoring is limited to front-office populations.

Aarti Agarwal

2 mins read • 11 September 2026