Operational risk and risk management across multi-jurisdictions for international banking group
Roll-Out of a Risk Framework Across a Banking Group
• Whilst the financial reporting and general finance
function was straightforward and heavily
influenced by accounting practice, other areas
such as deposits, equity backed investments,
account handling and even compliance were
going to be markedly different.
• Previous attempts at rolling out the system had
been flawed and ineffective due mainly to
the approach taken being too high level and
failure to engage the departments
at a meaningful level.
• The Framework fundamentals were sound and
universally acceptable but a solid understanding
of the differences between the banking and the
insurance world was required and demanded an
open and honest dialogue with the various heads
• A plan was formulated to deal with each part
of the framework and priorities were made
using customer importance as the main
criterion and ensuring that processes
were accurately recorded and the
controls were adequately described
• During the initial process identification and
evaluation, important lessons were learned
regarding common processes that cut across all
departments, and the time saving that could be
obtained by linking the sub-processes on a
platform for unique and discrete functionality.
• IT was obviously linked to every process from
cash deposits and withdrawals, investments
received and loan applications and draws.
• IT was split into facilitation and a
support function so that additional
discernment could be made across
• As nobody was likely to understand the processes
and controls like the process owners, they were
tasked with the mapping of the processes at a
high level with all potential risk areas an
appropriate controls at the required junctures.
• A peer test would be conducted with the 2nd in
command and a quality assurance function
supplied by us.
• Fully documented details of the processes
and a full evaluation of the control’s
design and functionality with the
relevant COSO apportioned category
was then uploaded to the central
repository for reference.
• When all processes were identified with unique
references, a quarterly process owner sign-off
and 6 monthly full review was scheduled for each
department. Changes were coordinated and
phased to provide no loss of material
functionality to customers.
• Senior management reviewed and approved
any changes recommended and reported
through the risk committee.
• Global HQ were in overall command
of all data and version control
management with trained local
support and liaison.
• The entire process then had to be interpreted and
adapted to the European Head Office, the Isle of
Man International Operation and a final review
and interpretation of the fiduciary function in the
• The commonality of the processes in the main
banking arena had provided timesaving and
commonality that was applied across the
other three areas.
• The entire process was started at the beginning
of September and scheduled for 6
months and the final documented
process was received before New
Years Eve – two month’s early!
• You are always dealing with the principal when
you are dealing with my firm. This means that I am the
relationship manager and there is no junior partner to
whom responsibility will be transferred. There is no
decreased accountability, no "hand-off" to a lessinformed colleague. If your interests are at stake
continually, shouldn’t you reasonably expect my
• We can usually provide resources on a "just in
time" basis. That is, our projects do not have to cover
excessive overhead, such as multiple offices, large
administrative backup, recruiting, partner perks, etc.
We are organized to efficiently provide everything that
you, as the buyer needs, but nothing more than that
which means that you are paying for value and results
and only minimum overhead.
• There is more likelihood of your privacy
and confidentiality being observed with
fewer people working on the project. We
(and/or the few people we might also involve)
are constant which means that there isn’t the
need to sift through dozens of differing
• We’re faster. We can respond to requests
quickly, and return all calls within four hours
which means to you that there is no need to
worry about a bureaucracy, delays and
unknown people on the other end of the
• Since we handle fewer concurrent projects than
larger firms, our attention is focused on the job at
hand. This means that you don’t have to
"compete" with another dozen or so of our
clients, which may be larger, paying more or are
more time-demanding. We structure our work so
that every client receives maximum
• Your investment is controlled. There is no
"meter running". We work for a fixed, valuebased, project fee. Large firms can’t afford to do
that as readily because of all the people involved
and their own insistence on measuring their
success by billable hours. We measure our success
by client objectives reached, not in “time units”.
• The expertise that larger firms use is often whitelabelling for them by a pool of consultants
available in the marketplace at any one time. We
select our consultants from practising
subject matter experts which means that
you obtain the same or better expertise for less
• Inevitably, we are less expensive. There
are economies to using someone who can base
their fees on each situation and not on a predetermined service scale or need for reaching a
practice quota. This means quite simply better
value to you.
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We will conduct an initial appraisal at our cost
– only charging for expenses (UK Only)
We will make a proposal based on our
appraisal with your outcomes and needs
We will discuss the precise scope with you
and provide you with a project price
We will complete the work to your original
scope and satisfaction
We have a wealth of Financial Services Experience, and due to
the remedial nature of our work forming over 60% of our
business and that is conducted under a Non Disclosure Regime,
we cannot demonstrate every client.
We can provide all manner of assistance in
• Initial risk assessment or audit — an initial analysis to
identify higher risk areas of the business and weaknesses
in procedures. We also do risk management design.
• Business development — business analysis advice or
advice on particular issues — for example, how your firm is
Treating Customers Fairly and an action plan for
implementing Conduct Risk across your business.
• Help with setting up procedures — for example procedural
manuals for recruitment, training and competence,
complaints handling and anti-money laundering. May also
include templates for disclosure documents, fact-finds and
• File audits — checks to ensure that procedures are being
followed and identify good practices and weaknesses
• Complaints Handling – cost effective and project managed
from start to finish making your response robust and
We can provide all manner of assistance in;
• Technical support — may include advice on particular
products or regulatory reporting. May be available in
various formats, including website, helpdesk and individual
• Training — for example competency assessments, training
opportunities or product risk guidance. May be online
support, regulatory updates or seminar based.
• Support on individual issues — for example in dealing with
a complaint, a financial promotion or a particular suitability
• Financial promotions (all areas of advertisement) - full
support which would include websites, brochures, DVD's,
email templates, client mail shots, adverts, contacting
existing clients and so on.
• Remedial work — helping to action remedial work
required by the FCA/PRA.
• And much more … just ask!
Tel (+44) 7092
We operate across the UK, Europe
and the Middle East.
Currently exploring opportunities in