This document discusses operational risk and challenges in Latin America. It begins by defining operational risk and Enterprise Risk Management (ERM). It then discusses some of the main challenges, including cost pressures leading firms to cut control functions, fraud and insider risk especially from rogue traders, and growing cyber risks as the leading cause of incidents shifts from human error to phishing, hacking and malware. The document provides frameworks for improving cyber risk management and best practices such as creating frameworks involving senior management, identifying and prioritizing threats, protecting data, implementing incident response procedures, and periodically reviewing cybersecurity coverage.
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2. 2
OpRisk is an evolving discipline
Principles/Sound
Practices
CCAR
Basel III
Vendor Management
Enhanced
Expectations for Risk
Governance
Today
It is the risk of
loss resulting from
inadequate or
failed internal
processes, people
and systems or
from external
events
Basel II
Its everything
that is not market
risk or credit risk
Early days
How well is operational risk understood in LATAM?
3. 3
Enterprise Risk Management (ERM) is a
risk-based approach to managing an
enterprise, integrating concepts of internal
control, the SarbanesOxley Act, and strategic
planning. ERM addresses the needs of various
stakeholders, who want to understand the
broad spectrum of risks facing complex
organizations to ensure they are appropriately
managed. It includes the management of
Operational Risks, Liquidity Risks, Credit Risks,
Market Risks, Regulatory & Compliance Risks,
Reputational Risks, Cyber Risk and others.
Operational risk is "the risk of a change in
value caused by the fact that actual losses,
incurred for inadequate or failed internal
processes, people and systems, or from
external events (including legal risk), differ
from the expected losses".
ERM and ORM
4. 4
Driven by internal factors
Creating an operational risk culture
Accountability and transparency
Risk technology infrastructure and data analytics Big Risk Data
Driven by major external factors
The future of AMA?
Regulatory demands (FACTA, DFA, AML, just to name a few)
Increasingly sophisticated cyber security threats
Political instability (Middle East, Brazil, Venezuela)
What are the main industry OpRisk challenges today?
6. 6
US economy growing modestly. EU stagnated.
FIs under pressure to reduce costs
Pressure should continue (expected GDP growth < 3%)
Focus on:
Resolving performance issues
Reducing downtime
Simplifying infrastructure (de-risking)
Fraud tends to rise in economic downturns
Earnings pressure
Rogue trader cases in volatile markets
Watch for cutting cost in non-revenue generating control functions
#1 Cost pressures: the pursuit of efficiency
8. 8
Notorious rogue trader cases:
Bruno Iksil (JPMC-2012) USD 5.8B
Kweku Adoboli (UBS-2011) USD 2.3B
Jerome Kerviel (SG-2008) 4.9B
Brian Hunter (Amarath Advisors-2006) USD 6.5B
Nick Leeson (Barings Bank-1994) 827M
Typical environment:
Aggressive culture
Compensation tied to short-term performance
Routine control breaches
Insufficient challenges from control functions
High volume of trades supported by fragmented IT systems
Complex products poorly understood by Senior Management
#2 Fraud and Insider Risk
10. 10
Human error is no longer the leading cause of cyber incidents, the number
one spot has been taken by Phishing, Hacking, and Malware in 2016
Source: 2016 BakerHostetler Data Security Incident Response Report
3 Cyber Risk
11. 11
Board Engagement and Oversight Model Six Components
Source: KPMG Cyber Maturity Framework
3 Cyber Risk
15. 15
Where do we start?
1. Create frameworks that involve senior management, incorporate the organizations risk tolerance,
and allow for risk assessments that help improve the framework over time.
2. Identify the sources of potential cybersecurity threats and prioritize the areas in most need of
improvement given the organizations risk tolerance.
3. Take specific actions to protect software and hardware that contain data, especially data subject to
cybersecurity threats.
4. Implement procedures for responding to cybersecurity incidents and define roles for individuals in
charge of incident response.
5. Take a risk-based approach to selecting, engaging, and monitoring third party service providers.
6. Provide employees and other authorized users of the organizations systems with training appropriate
to their specific responsibilities and the types of data they may access.
7. Create and deploy an effective cyber intelligence program using all resources available to the
organization.
8. Periodically review the adequacy of an organizations cybersecurity coverage to determine if the
policy aligns with threats identified by the organizations risk assessment(s) and ability to bear losses.
Organizations that do not have cyber insurance should evaluate the cyber insurance market to
determine if coverage is available that would enhance the organizations ability to manage the
financial impact of a cybersecurity event.
Best Practices