I sistemi dei controlli interni di fronte alle nuove sfide: nuovo sviluppo o declino ?

The article analyses the internal control systems of the banks. The role of internal control system inside the equilibria of the banks and their relationships with other firewalls (es. capital adequacy) are made clear. In the interpretation of the past and future evolution of the system, the life-cycle model is used and applied to managerial systems. The development path of internal control systems are illustrated, from the introductory and development stage (regulation and its evolution), to the maturity stage (the current financial crisis), to the decline or renewal stage (improvement of the systems). The regulation is critically analysed, both the general rules issued by international bodies such as Basel Committee and national regulation from Banca d’Italia. The critical areas and ambiguities are identified: differences from Basel and Banca d’Italia approaches, overlapping and stratificaton of different national laws, problems and ambiguities in definition, objectives, functions and perimeter of the system, roles of control functions (sometimes conflicting or unclear). The lesson from the crisis is studied (weaknesses of the systems, risks ignored or undervalued). One of the solutions proposed by the author is a new conceptualisation and design of the levels of control, introducing and stressing the importance of the “zero level”, i.e. self control and ethical behaviour of individuals