About

Every business operating across borders carries regulatory risk: the possibility that a change in law, policy, or supervisory posture will materially reshape the environment in which it operates. For banks, this risk is unavoidable. As custodians of public funds, banks sit at the intersection of prudential regulation, monetary policy, and, for those operating in or through South Africa, exchange control. Few sectors are watched as closely, or reshaped as often, by regulatory change.

I am Graham Prior, and I spent my career inside that system. I worked at the South African Reserve Bank in both the Financial Surveillance Department (Exchange Control) and Bank Supervision, and later headed Banking Compliance for the FirstRand Banking Group, thereafter my focus moved to assisting with enabling business within international regulatory frameworks for the Group and corporate clients of the Group. Regulatory-Risk.com is where I now write about what I experienced: how regulation is made, how it is applied in practice, and where the gap between the two creates risk, or opportunity, for the businesses that have to live with it.

The site covers three related fields.

Banking regulation tracks the prudential and governance frameworks that determine how resilient the banking sector actually is, as opposed to how resilient it appears on paper: capital and liquidity standards, the Basel reforms and their local implementation, and the relationship between the Prudential Authority and the banks it supervises.

Capital controls looks at the other side of the same coin: exchange control and cross-border capital flow management, an area with a long and still-evolving history in South Africa. This runs from the mechanics of SARB FinSurv administration to the gradual liberalisation of the exchange control regime, and what that liberalisation does and doesn’t do for capital mobility, currency stability, and investor confidence.

Governance and regulatory failure examines what happens when the frameworks break down: the collapse of state-owned enterprises, business rescue, and the distance between accountability on paper and accountability in practice. The South African Post Office is one running case study; it will not be the last.

Running beneath all of this is a fourth thread, business matters, which is less about regulation than about how to think. Mental models, first-order and second-order consequences, the Pareto principle: these are the tools I relied on throughout my career to cut through complex regulatory and business problems, and I write about them here because analysis is only ever as good as the thinking behind it.

These fields move constantly. A capital adequacy rule finalised this year will be revised within a decade; an exchange control relaxation announced in a Budget speech takes years to work through into actual market practice. My aim is to track that movement as it happens, with the benefit of having sat on the supervisory side of the table, and to make the practical implications legible to the businesses, boards, and practitioners who have to manage the consequences.

If what you read here is useful, you may also follow by subscribing on Substack, where my analysis appears first. I also publish on Medium.