Abstract This panel explored the legal design and operation of banking crisis management frameworks worldwide, comparing European, British, Asian and Brazilian experiences. While the Banking Union framework in Europe has matured under the Bank Recovery and Resolution Directive (BRRD) and the Single Resolution Mechanism, panellists highlighted persistent fragmentation, limited flexibility and differing accountability standards, in other jurisdictions. The debate highlighted the diversity of institutional arrangements, the renewed reliance on transfer strategies, the uneven application of bail-in tools and the emerging use of deposit insurance funds as resolution backstops. Lessons from the 2023 turmoil – particularly Silicon Valley Bank UK – revealed how liquidity provision, recapitalisation mechanisms and cross-border coordination continue to shape credible banking crisis management regimes. The session concluded that global convergence of resolution principles is advancing, but still constrained by domestic legal and institutional particularities.
Barata et al. (2026) studied this question.