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The Age of Accountability
Turning compliance into a personal risk
There’s quite nothing like watching a compliance doctrine evolve in real time.
For years, the narrative in Asia’s financial centers was about institutional accountability: billion-dollar fines, compliance remediation plans, and corporate mea culpas that mostly hit shareholders.
But that story is changing. Regulators across the Asia-Pacific region are starting to view individual accountability as the true deterrent.
And nowhere is that shift clearer than in Singapore, where two bankers are now serving jail time for their roles in the city-state’s record SGD 3 billion money-laundering case.
Singapore’s Criminal Turn
Wang Qiming, a 28-year-old former Citibank relationship manager, is serving 24 months for forgery and aiding illicit fund flows, including deleting WhatsApp messages in a futile attempt to cover his tracks (Source).
Liu Ka, formerly with Julius Baer, is serving four months for abetting a forged tax certificate tied to one of the main suspects (Source).
These cases mark a profound shift in tone. Research long showed that personal prosecutions send a much stronger signal than any civil penalty could. Going forward we shall observe this much more often in practice.
Australia’s Boardroom Battles
Australian regulators seem to have adopted a similar approach. AUSTRAC and ASIC now coordinate: one brings civil AML/CTF actions against institutions, the other invokes directors’ duties under Section 180 of the Corporations Act to pursue executives personally.
The Star Entertainment Group case is the blueprint. AUSTRAC’s 2022 lawsuit over casino AML failures dovetails with ASIC’s action against 11 former directors and executives. So far, Chief Casino Officer Greg Hawkins has paid AUD 180,000 and accepted an 18-month ban; CFO Harry Theodore paid AUD 60,000 and took a nine-month ban. Nine others remain in court, accused of being “merely ornaments” to governance (Source).
This approach builds on AUSTRAC’s AUD 2.56 billion legacy of fines across banks and casinos. But its new focus is precision-guided: hit the decision-makers.
The Regional Ripple
Singapore and Australia aren’t alone. In Hong Kong, the SFC maintains a list of current disqualification orders (Source). In Japan, the FSA has warned that executives could face personal liability for AML oversight failures.
Global pressure seems to be among the key drivers of this process.
With the FATF’s fifth-round mutual evaluations underway, regulators must demonstrate effectiveness. Not just in numbers, but in outcomes that change behavior.
What This Means for Compliance Teams?
For risk and compliance professionals, the era of personal accountability is both threat and opportunity.
Training is no longer optional. Relationship managers and onboarding teams must understand that ignorance is not a defense.
Boards can’t delegate tone. Director-duty cases show that “oversight” now means active engagement.
Front-line vigilance matters. Regulators are following the paper trail to whoever touched it last.
Fear can be a teacher. Jail terms create clarity about risk far faster than audit reports.
And beyond deterrence, this shift opens a window for compliance leaders to re-engage staff, moving beyond checklists towards a shared ownership of risk.
Parting Thoughts
Asia’s regulators align enforcement with accountability, replacing passive compliance with personal consequence. Singapore’s prosecutions and Australia’s director bans represent two ends of the same spectrum, united by one message: someone must own the failure.
Personal risk has become the new compliance currency. It’s no longer enough to have strong controls on paper.
The real question is whether such controls can be defended in court?
Thanks for reading.
Alexey