Grandeur et décadence de la fonction déontologie. Une perspective sur le contrôle interne bancaire et financier

This paper studies the evolutions witnessed by the compliance function within French credit institutions and investment firms, between 2003 and 2006. Based on a qualitative study involving participant-observation and secondary data analysis, we shed light on the coexistence of two conceptions of internal control: one rooting in the notion of ?déontologie? (or an ex ante approach), the other in the notion of control (or ex post verification). From a theoretical perspective, our analysis draws on works by Paul Ric?ur relating to the articulation of ethics and morals, with a view to contributing to the literature on internal control in the banking and financial sector. We show how the introduction of the notion of non-compliance risk in the French regulations in 2005 changed the compliance function. Our analysis questions such evolution, promoting normative conformity over a more practical understanding of normative monitoring.