BANKING SYSTEMS OF FOREIGN COUNTRIES AND LEGAL BASIS OF CORPORATE GOVERNANCE OF BANKS (ON THE EXAMPLE OF THE UNITED STATES, GERMANY AND JAPAN)
Keywords:
corporation, corporate governance, commercial bank, bank management, bank council, corporate governance code, central bank, banking supervision, bank audit, remuneration committee, keiretsu.Abstract
In this article, the author tries to explain corporate governance in commercial banks of the world’s leading countries, its legal framework, the specifics of corporate governance in commercial banks, and its importance. The article explains the terms and concepts of corporate governance, the role of different governing bodies in corporate governance in commercial banks of the world’s leading countries, the practice of their organization, as well as a comparative analysis between them. The article analyzes the experience of the United States, Germany and Japan, the world’s leading countries in corporate governance in commercial banks, how the governing bodies of commercial banks are formed in these countries, their role in corporate governance and the legal framework of corporate governance. The differences between the corporate governance of commercial banks and the governance of other corporations are revealed. Based on the three models recognized in corporate governance (Anglo-Saxon, German and Japanese models), the organization of bank governing bodies, their activities and priorities are shown. The author also provides practical and legal recommendations for the introduction of foreign experience in this field in the local system, and the author’s conclusions.

