금융사지배구조법상 책무구조도의 한계와 개선방안에 관한 연구

Triggered by recurring large-scale embezzlement, breach of trust, fraud by executives and employees, and incidents causing harm to financial consumers, the demand for strengthened internal controls and enhanced managerial accountability within financial institutions has intensified. In response, financial authorities introduced the responsibility map through the Act on Corporate Governance of Financial Companies in July 2024, mandating senior executives to predefine and disclose their internal control responsibilities by business area to supervisory authorities. This framework, adapted from international internal control practices in the UK and Australia, emphasizes clarifying accountability in the event of incidents and reinforcing the responsibility of senior executives. This study critiques the responsibility map for its over-reliance on document-based segregation of responsibilities and post-incident sanctions, which may incentivize concealment of incidents, offer insufficient preventive measures, and suffer from weak regulatory enforcement. Analyzing experiences from early adopters in the UK and Australia, the study argues that merely imposing retrospective accountability is inadequate for substantive improvements in internal control or for preventing senior executives from evading responsibility. To realize the core objectives of the responsibility map, the study advocates balancing the distribution of executive authority and responsibility, enhancing proactive regulatory oversight, and strengthening the independence of compliance officers. These efforts aim to contribute to effective prevention of financial misconduct and bolster trust in financial markets.