The financial sector is undergoing a major shift with the implementation of the 'Responsibility Structure' (Financial Responsibility Map). This new system marks a significant departure from the traditional approach, where accountability for financial incidents often stopped at the individual employee or their immediate supervisor. Under the new framework, executives assigned to specific duties will be held directly and legally responsible for major failures, such as IT outages or significant financial accidents.
To avoid or mitigate potential sanctions, executives must proactively demonstrate their oversight. Simply claiming ignorance ('I didn't know') is no longer a valid defense. Instead, they must provide concrete evidence of their internal control activities. Crucial evidence includes IT system logs showing approved internal control checks, written executive opinions, and digital approval timestamps. The guidelines emphasize that internal control is a core executive duty that cannot be delegated to subordinates.
Furthermore, even CEOs will face distinct legal responsibilities as the final authority in the internal control chain. Attorney Seong-min Kwon from Law Firm Hoam emphasizes that successful compliance depends on moving beyond formal documentation. Financial institutions must genuinely integrate a culture of internal control and compliance into their daily management processes to ensure the system functions as intended and provides actual legal protection.