By Anupam Sonal
Anupam Sonal, former Chief General Manager at the Reserve Bank of India, is currently Senior Advisor (Regulation, FinTech & Compliance) to Scheduled Commercial Banks.
September 3, 2025 at 6:18 AM IST
In 2005, the Basel Committee on Banking Supervision reminded the industry that compliance was never about forms and files. It was about ethics as the engine of resilience, the anchor of trust. Two decades later, this has become less a cautionary footnote and more the central story.
From Silicon Valley Bank and Credit Suisse to Yes Bank and Wells Fargo, the failures that scarred the past two decades all shared a pathology: lapses in compliance. Even the Global Financial Crisis and the European Sovereign Debt Crisis were less about credit or fiscal implosions than about systemic neglect of prudential and governance obligations. Across geographies, the lesson has been consistent: banks that treated compliance as a ritual or defense, rather than a foundation, saw trust evaporate faster than liquidity.
Structural Core
While resilience is usually measured in ratios and capital buffers, it is compliance that guarantees that these numbers remain sustainable. Properly understood, compliance is not an appendage, it is the bank’s living constitution, the evolving charter that holds its strategies, decision-making and trust together. When that nervous system falters, stability and reputation erode, often irreversibly.
As competition intensifies, especially from nimble technology start-ups, customer trust will function as the ultimate differentiator—a bank’s reserve currency, convertible, yet depletable with a single lapse. This makes compliance the trust-battery that powers performance and decides survival in crowded markets. Banks, therefore, need to champion compliance as an enterprise-wide priority, ensuring that its ethos permeates down to every unit and every frontline employee. This shift elevates compliance as the bank’s internal intelligence grid and an embedded capability.
While the principles laid down in global frameworks remain foundational, they are no longer adequate. To build the next tier of resilience, banks must move beyond static compliance and embed it with innovative tools, real-time intelligence, predictive analytics, coupled with forward-looking practices that make compliance proactive rather than reactive. Rigorous risk assessments must remain at the core, enriched by stress testing, scenario analysis, and early-warning triggers that allow the compliance function to anticipate rather than just respond.
A future-facing model rests on the new syntax:
Fiduciary Shift
Syntax, however, is meaningless without altitude. Compliance must find its seat at the top table. Boards and CMDs must act not as ceremonial overseers but as custodians of regulatory credibility. The Chief Compliance Officer, in this framework, contributes as an architect of integrity, who maps the uncharted terrain of risks and guides the institution.
Resilience will not be measured only in continuity drills or capital ratios, but in demonstrable tolerance for shocks, in how swiftly obligations are met, and in how seamlessly partners and third parties are integrated into the bank’s compliance nervous system. Above all, data integrity—the single point of truth—must form the core, without which compliance risks dissolving into fiction.
Some tools could accelerate this shift:
From tokenism of “compliance director” to a proactive, compliance-savvy board sub-group that anticipates regulatory expectations.
Why This Matters
In an era where risks migrate in milliseconds, customers switch loyalty with a swipe, and algorithms trade faster than human instinct, compliance can no longer be an afterthought. It must be the bank’s circulatory system, oxygenating culture and sealing fissures before they threaten collapse.
The banks that shape tomorrow will not be those with the largest balance sheets alone, but those whose compliance DNA can channel disruption into credibility. In the evolving financial order, compliance will not sit at the edge of strategy; it will be the force that keeps strategy viable.
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