enterprise risk management for us operations of international banks communication and education

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Enterprise Risk Management for US Operations of International Banks Communication and Education M adison C onsulting G roup

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Enterprise Risk Management for US Operations of International Banks Communication and Education. Enterprise Risk Management. Challenge: Effectively managing all risks of US Operations while meeting both regional and enterprise requirements concurrently. Market Risk Credit Risk - PowerPoint PPT Presentation

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Page 1: Enterprise Risk Management for US Operations of International Banks Communication and Education

Enterprise Risk Management for US Operations of International Banks

Communication and Education

Madison Consulting Group

Page 2: Enterprise Risk Management for US Operations of International Banks Communication and Education

2Madison Consulting Group

Challenge: Effectively managing all risks of US Operations while meeting both regional and enterprise requirements concurrently

Enterprise Risk Management

Market Risk

Credit Risk

Operational Risk

Legal and Regulatory Risk

Page 3: Enterprise Risk Management for US Operations of International Banks Communication and Education

3Madison Consulting Group

Enterprise level market and credit risk management programs in force are generally well established

Market and Credit Risk Management

Market Risk

Credit Risk

Operational Risk

Legal and Regulatory Risk

It is a core competency of financial institutions to effectively manage market and credit risks. The recent challenges have been marked by liquidity issues and lack of reliable market data, highlighting continued dependency on human judgment factors and the need for greater transparency.

Page 4: Enterprise Risk Management for US Operations of International Banks Communication and Education

4Madison Consulting Group

Increasing emphasis on operational and legal/regulatory risk management have increased the urgency to addressing human aspects of these risk programs

Operational and Legal/Regulatory Risk Management

Market Risk

Credit Risk

Operational Risk

Legal and Regulatory Risk

US legal framework and regulatory oversight has placed much greater emphasis on operational (Sarbanes-Oxley) and legal/regulatory (BSA and Patriot Acts) risks, forcing financial institutions to enhance these enterprise programs to encompass these new requirements.

Page 5: Enterprise Risk Management for US Operations of International Banks Communication and Education

5Madison Consulting Group

“Indifference” Risks

The risks of home office not understanding and integrating US market issues and requirements can potentially result in cost and/or reputational consequences

Continue operating under existing enterprise risk management programFailure to

integrate US issues and requirements in the enterprise risk program

Create supplemental risk management programs customized to meet US issues and requirements

Insufficient controls from US regulatory perspective will risk reputation exposure – written orders and fines

Duplicate expenses Compliance Administration Technology

Page 6: Enterprise Risk Management for US Operations of International Banks Communication and Education

6Madison Consulting Group

Two-Way Education

A key challenge for management of US Operations is to communicate and help educate home office where US issues and requirements may differ from the existing enterprise risk management framework

Enterprise Risk Program

Market and credit risk management Operational risk management program Customer identification and verification documentation program Anti-money laundering monitoring program

US Issues and Requirements

US market and economic conditions and trends Sarbanes-Oxley Patriot Act Bank Secrecy Act / Anti-Money Laundering Requirements and

Regulations

Page 7: Enterprise Risk Management for US Operations of International Banks Communication and Education

7Madison Consulting Group

Key to Success – Education Strategy

Not just training, but educating staff to make informed decisions Understanding both process and policy issues

Continuous education to meet rapid market changes Top down and bottom up input into program content

On-the-ground findings from operating staff Front-line feedback from the market and regulators

Integration of education program across home office and all regions Program consistency across the enterprise Ensuring staff understand relationship between local and

enterprise requirements

A well designed education strategy will improve the effectiveness of the enterprise risk programs and ensure the programs evolve as requirements change

The goal of an effective education program is to make the staff the key component of a successful enterprise risk management program

Page 8: Enterprise Risk Management for US Operations of International Banks Communication and Education

8Madison Consulting Group

“Outside the box” thinking of how to develop and effectively manage an education strategy for the enterprise risk programs

Education Program Example

Using social networking construct Wiki based education modules to permit dynamic updating Blogs to inform on latest market and regulatory issues Personal pages of staff informing key areas of expertise “Latest news” for ongoing communication between regions

and home office on key areas of interest and concern Topic examples

Global economic risks Risk and pricing models BSA/AML regulatory findings and issues Operational risks and losses

Page 9: Enterprise Risk Management for US Operations of International Banks Communication and Education

9Madison Consulting Group

Issue Example (1)

Lack of understanding by home office of importance placed in US on accurate and detailed customer typing, results in US regulatory finding of inaccuracies for home office customers conducting business in the US

Customer Typing Information

Home Office

N, C, S America

Europe

Asia

BSA/AML Customer Identification Program

Management and Financial Reporting

Regulatory Reporting

Page 10: Enterprise Risk Management for US Operations of International Banks Communication and Education

10Madison Consulting Group

Issue Example (2)

An un-integrated education program, where training provided to staff was limited to local region procedures for collection of KYC verification documentation, results in US regulatory action because US clients originating elsewhere were not adequately on-boarded originally, or re-boarded in the US, to meet US KYC requirements.

RegionA

RegionB

Region C Credit

Know-Your-Customer Documentation

Page 11: Enterprise Risk Management for US Operations of International Banks Communication and Education

11Madison Consulting Group

Madison Consulting Group30 Montgomery StreetJersey City, NJ 07302

201-434-5678

Bernard ChenPartner

[email protected] (c)