INTERNATIONAL POLICY ANALYSIS Reforming Bank Governance »Top-Down« Reform and Bank Resistance MARCUS STANLEY September 2018 n The 2008 financial crisis laid bare serious issues in the governance of banks and fi­nancial firms, as regulators were confronted with widespread misconduct and a lack of effective internal risk management. n In response, regulators focused on reforming the traditional top-down corporate governance framework operating through the board of directors, despite the short­comings of this approach for highly leveraged institutions such as banks. n Looking back at the failure of reforms since 2008, this paper proposes ways in which »regulation from below« by engaged and empowered bank workers can provide an alternative to a purely»top-down« approach and strengthen efforts to improve bank governance, and therefore the health of the global economy.