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When Culture Becomes a Control — How Supervisors Are Shaping the Future of Operational Risk
In regulatory circles, culture is no longer an abstract concept. It’s a measurable, reportable, and enforceable risk factor—viewed not as a soft HR issue, but as a core element of operational control. Across Australia, Europe, the UK, and the United States, financial and non-financial regulators are making it clear: the management of culture and conduct is now fundamental to operational risk oversight.
This shift is transforming the way Operational Risk Management (ORM) functions are being evaluated. Regulators are demanding not only documentation of controls but evidence that organizations understand how risk culture shapes operational performance, compliance behavior, and escalation pathways. In response, forward-looking ORM programs are moving beyond control testing and loss event tracking. They are building integrated risk intelligence systems that can monitor, measure, and adapt to the human dynamics of risk.
Culture as Capital Risk — Lessons from the ANZ Breakdown
Now that intangible risks are becoming materially consequential, few cases better illustrate the price of cultural failure than the one unfolding at ANZ. In March 2025, the Australian Prudential Regulation Authority (APRA) imposed a $1 billion capital charge on the bank, citing persistent governance failures and an organizational culture that allowed misconduct to fester unchecked.
This was not a case of financial fraud or a high-profile cyber breach. It was the slow erosion of internal accountability—fueled by poor leadership, ineffective escalation channels, and a widespread underestimation of non-financial risks. As APRA Chair John Lonsdale put it, ANZ’s problems were “persistent and prevalent,” with echoes of similar issues already observed at its peer institutions.
The implications extend far beyond Australia’s banking sector. The ANZ case is a clear signal to global risk leaders: organizational culture is now a capital issue.