Overview of Key Operational Risk Issues
- The impact of operational risk on the organization
- Regulatory focus on issues relating to misconduct of management and employees
- Systems of accountability, responsibilities bounded by safety thresholds, alerts, disciplinary guidelines, sanctions for violation
- Implementing an organizational structure
- Estimating probability of adverse outcome and loss to business
- Determining the direct and indirect effects of an adverse outcome
- Separation of risk compliance function from P&L targets
- Cyber risks – internal vulnerabilities, integrity of software systems, third party risk, outsourcing, cloud computing, phishing, etc.
Adverse Consequences from Operational Failures
- Reputational risk
- Legal risk
- Litigation risk, fines, and class action lawsuits
- Rogue trading – Soc Gen, UBS, ineffective back-office controls
- Avoiding overly complex instruments
Root Cause Analysis
- Identification of underlying causes for operational failures
- Forensic and systematic analysis of large-scale failures and near failures
- Data mining approaches and timeline sequences
- Transforming from a reactive approach to operational failure to a pro-active approach
- Prioritizing amongst multiple root causes
- Process mapping
- Establishing the relevant metrics for each root cause
- Checks to ensure that action plans would alleviate or mitigate symptoms arising from root causes
Addressing Cyber Risks and Vulnerabilities in Business Processes
- Core concepts in the architecture of enterprise software, especially systems integration and security issues
- Principal sources of cyber risk – internal and external
- Risks associated with introducing new business systems
- Risks associated with introducing new products
- Opportunities and challenges presented by new, disruptive technologies – blockchain, AI, Big Data analytics, machine learning
- The cultural divide between IT “tech” staff and senior management
- Business process re-engineering (BPR)
- Differentiation between prevention and managing negative outcomes.
- Cloud computing and outsourcing – Amazon Web Services
- Change management – implementing new requirements on privacy, GDPR etc.
Methodologies for Measuring and Modelling Operational Risks
- Loss Modelling Methods – contingency scenarios
- Templates for collecting loss data
- Using Scenario Based Analysis (SBA) for filling in gaps in data
- The role of Business Environment Internal Control Factors (BEICF’s)
- Scarcity of historical data in the outliers for operational losses
- Different distributions for modelling severity of losses
- Monte Carlo based loss scenarios
- Stress testing methodologies
- Data limitations involved in quantifying operational risks
- Segregating internal versus external software failures
Risk Control Self-Assessment (RCSA)
- Templates for collecting loss data
- Using Scenario Based Analysis for filling in gaps in empirical data
- Questionnaires – alerts to potential risk areas and points of failure
- Conducting an RCSA Workshop – role of facilitators, experts, back office
- Internal Reporting mechanisms – iterations, validation protocols
- Key Risk Indicators – developing new KRI’s and following peer groups.
- Reporting protocols
- The role of Business Environment Internal Control Factors (BEICF’s)
- Developing templates for Scorecard based risk assessment
- Discrete versus continuous data is used for the modelling
- Explanation of Poisson distribution for occurrences of operational losses
- Different distributions for modelling severity of losses
- Application of a lognormal distribution
Overview of Scenario Generation for Stress Testing
- How to generate and calibrate shocks and adverse scenarios
- Simulations – randomized market scenarios expressing risk factors
- Macro factors – establishing associations with broad macro-economic variables
- Expert judgment – qualitative and forward looking
- Identification of key risk factors
- Associating probabilities to risk factors – quantitative and qualitative approaches
- Mapping qualitative and descriptive data to numerical values
- Identification of worst-case scenarios
- Data deficiencies and estimation of outlier scenarios
Fundamentals of Business Ethics
- Ethics as moral principles which govern good behaviour
- Distinguish between ethical issues and legal issues
- Business ethics and corporate social responsibility (CSR)
- A socially responsible firm should be an ethical firm and vice-versa
- Responsibility to all stakeholders and not just shareholders
- How do businesses ensure that directors, managers, and employees act ethically?
- Codes of conduct and best practice
- Environmental policy and actions
- Rules for personal and corporate integrity
- Is the corporation a moral agent?
Financial Crimes and Anti Money Laundering
- Surveillance of financial services sector by regulatory bodies
- Know Your Customer (KYC) and Anti-Money Laundering (AML) remediation
- International context for Anti-Money Laundering (AML)
- Focus on Counter Terrorist Financing (CTF)
- Legal, regulatory, and supervisory frameworks underpinning AML/CTF
- Money Laundering Reporting Officer (MLRO)
- Transaction Monitoring and Filtering Framework
- Suspicious Activity Reporting
- Senior Management Responsibility regarding AML/CTF
- Role of banking supervisors
- Sanctions provisions and “blacklisted” territories and individuals.
- Tax avoidance – FATCA
- Consumer protection focus – SEC, FCA, CFTC, EU Commission
Public Policy and the Role of Financial Regulators
- Balancing regulatory compliance and internal best practice
- Increasing focus on macro-prudential regulation – stress testing
- Role of political action groups and commercial lobbying
- Surveillance of financial services sector by regulatory bodies
- Focus on boundaries between financial crime and operational vulnerabilities.
- Examination of the robustness of procedures to avoid money laundering.
- Description of $10 billion fine to BNP Paribas for dealing with clients in countries on US “black list”
- Capital adequacy, Basel III, role of banking supervisors
- Miscellaneous risks arising from government/supra national actions
Basel Approaches for Operational Risks
- Basel Basic Indicator Approach (BIA) and Standard Approach (SA)
- Explanation of the Basel III Advanced Measurement Approach (AMA)
- Scenario Based Approach (SBA)
- Loss Distribution Approach (LDA)
- Business environment and internal control factors (BEICFs)
- Role of senior management in identifying adverse scenarios
- Distributions for occurrence and severity of losses
- Basel III Business Line and Event Type Codes
- Process Mapping – mapping processes to appropriate regulatory categories
- Templates for data capture for Basel compliance and internal reporting
- Role of external data – scaling of comparable institutions
The New Basel Standardized Approach for Operational Risk
- BCBS documents on revisions to op risk approaches
- Explanation of the Business Indicator metric
- Non-linear scaling of operational risk to total revenue of a bank
- Using absolute values for estimating bank’s exposure to operational risk
- Review of the BCBS Operational risk Capital-at Risk (Op CaR) model
- Internal Loss Multiplier and Loss Component
Enterprise Risk Management and Reporting Systems
- Enterprise-wide risk control environment
- Risk assessment process
- Credit policy and levels of authority for credit decision making
- Monitoring/reporting mechanisms within banks
- Risk control systems
- Holistic views regarding risk
- Avoidance of silos
- Monitoring of controls
- Role of internal auditors
- Role of the Chief Risk Officer
Best Practice in Enhancing Risk Culture
- Risk control systems
- Risk governance philosophy
- Ethical principles
- Codes of conduct
- Human resources personnel
- Ongoing professional development
- Diversity of perspectives
- Rewards and bonuses