Compliance risks are defined as the risks that result from violations of laws, regulations, codes of conduct, or organizational standards of practice. Compliance risk management is a part of compliance management and it helps identify, assess, and monitor and manage risks that might cause because of non-compliance. Compliance requirements differ from sectors to sectors. The government and regulatory agencies specify rules and regulations based on which companies in a particular sector should do business. For example, banks and financial institutions face the most complicated regulatory environment.
There are three layers to compliance: Compliance with regulations, standards defined by various organizations and industry groups, and internal policies. The most stringent compliance tier is compliance with regulations. The regulatory requirements are rules that the government impose on organizations. Both federal and state governments define rules and regulations that govern the conduct of companies and how they interact with customers and employees. One of the typical examples of a regulation that a company should publish financial statement every quarter. The second layer of compliance risks are the standards that put forth by international organizations and industry groups. For instance, companies need to follow ISO standards and deliver products and services that meet regulatory and customer requirements. To be certified in ISO series of standards, a company should adhere to the requirements outlined by the International Organization for Standardization. The third layer is the internal policies that an organization establishes to perform efficiently and effectively and to keep up with the regulations.
Compliance officers need to assess and understand the risk of non-compliance. Some of these risks need to be prioritized and addressed aggressively as they might result in huge fine, reputational damage that companies might not be able to recover from. For instance, the US banking regulators fined Citigroup $400 million on Thursday for "longstanding failure" to fix its data and risk management systems recently. So, the first and foremost step is to understand what your organization’s compliance risks are, how have they become risks, rank risks based on the priority and create a compliance risk management plan to address these high priority risks.
Successful compliance risk management programs adopt a risk-based approach to achieve its goals. Compliance officers identify the priority compliance risks and implement controls to address them. It allows the compliance teams to focus on the compliance risks that matter to them the most. They can tailor their compliance programs to make them ready to respond to risks rapidly. VComply is a leading GRC platform that helps meet the demands of compliance professionals by helping them perform risk assessment and implement controls.
Historically, the banking sector has always been plagued by vulnerabilities and risks. The global financial crisis of 2007 and 2008 is an indicator of this fact. Robust risk and compliance management programs and use of technology have helped banks to make good progress on the risk management front. While these control systems and risk management protocols are constantly evolving, operational risk always remains a concern.
From the ever-present threat of fraud, both internal and external, to the sophisticated cybersecurity risk, banks today, have numerous weak spots. This may be primarily due to the fact that financial entities are trying to stay on par with the ever-evolving digital landscape and this dynamic environment is relatively unexplored. Operational risk has been an independent risk category for just 2 decades now and the shifting sands of the virtual space does banks no favors.
Inherently, managing operational risks as a bank is a herculean undertaking. Some of the common roadblocks include:
All these are present in today’s environment and the integration of digitization only opens doors to more vulnerabilities. Even though improved access to data and better analytics has and can be leveraged to improve operational risk management, some of these risks might just be here to stay. For greater insight, here are the top operational risks in banking.
It is quite common for today’s financial institutions to rely on third-party providers for a range of services. These may be employed to better the experience customers enjoy or add to the arsenal of features on offer, but with these advancements comes serious risks. Banking institutes have to vet these providers to ensure that their vulnerabilities don’t spill over to the main enterprise.
Going one step further, total responsibility is usually that of the contractor as they are the ones that face the reputational damage that follows a breach. This means, controlling third-party risks also involves evaluating the risks associated with any vendors used by the third-party provider in question. This highlights the sheer complexity of managing operational risks in the banking sector.
These are a form of operational risk that stems from a number of vulnerabilities and poses a threat to the entities’ financial condition, both current and projected. Fraud can arise from either:
Fraud is mostly intentional, and is carried over long periods of time, sometimes even years. The losses incurred due to these crimes is difficult to determine mainly because it doesn’t stop at knowing the direct financial losses. Other factors such as the loss of productivity, investigation expenses, both cost and time, legal and compliance costs, and loss of reputation also get added into the mix for an even greater capital loss. But, thanks to the new technology, primarily machine learning, there is a way to mitigate such losses.
As per data published by McKinsey & Company, a North American bank was able to identify such risks and get ahead of them before it was too late. This bank used advanced-analytics models to monitor behavior and know its risk exposure from its retail salesforce. This method unearthed unwanted anomalies from the 20,000 employees it gathered data from.
With the pressure to go digital and keep up with the convenience and simplicity of service offered in the market, banking entities have their work cut out for them. This also applies to FinTech firms looking to give their customers the easiest and quickest experience. But this transformation to the digital sphere isn’t one without security concerns. This type of undertaking has several risks involved, including:
With digitization now taking its place as a mainstay in most sectors, it is no surprise that it comes with its own set of risks. Even despite the proactive risk management protocols or cybersecurity controls in place, phishing, ransomware and other such risks are still a threat. In fact, these risks have become more effective and occur more frequently. Data suggests that such attacks have tripled in the last 10 years and will continue to do so for as long as there is a reliance on digital finance services.
To make matters worse for financial institutions, antagonistic governments are known to orchestrate hostile activity around the financial services sector. Crippling these systems causes widespread disruptions and the losses are huge. A report from Accenture and the Ponemon Institute titled, ‘Unlocking the Value of Improved Cybersecurity Protection ’suggests that cyber risks, and the subsequent attacks that follow, are the highest in the banking industry and can amount to a whopping $18.3 million yearly, per company.
Data privacy and its security is of key importance to the banking sector and it is also a facet that has been closely followed in the news. Part of the reasons for this being the 2020 California Consumer Privacy Act (CCPA) and the EU’s General Data Protection Regulation (GDPR). However, when it comes to data privacy, the problem lies with data management. Considering that most banking entities have their data siloed, there is a gap created between this data and governance processes. This is a base-level vulnerability as AI-enabled systems face crucial data shortages that undermine its function.
While banking entities have every incentive to minimize operational risks, this is difficult to sustain. If neglected, banks risk more than just the loss of capital. In some cases, customers lose their trust in the entity and this hurts banks by restricting business or future deposits.
Incorporating operational risk management into the overall enterprise risk management framework is a systematic process and is one that must have its own tools and organization. This is where an all-in-one solution like that from VComply offers value. The platform provides a GRC suite that offers effective risk management frameworks and controls, while revolutionizing management of regulatory compliance. This tool enables seamless digital collaboration and gives you real-time risk management solutions.
An organization needs to analyze risks that might occur and find ways to prevent them or reduce their impact. It helps them to act confidently on essential business decisions. Risk management is the identification, assessment, and prioritization of risks and taking steps to reduce risks to an acceptable level. In first, organizations need to identify and prioritize risks. Once they identify the risks, they need to conduct an in-depth assessment of risks. A risk assessment matrix plays a significant role in risk management. It is an essential tool that helps identify and prioritize risks by evaluating the likelihood of a risk occurring and the severity of each risk if it were to happen. It is a method of improving the visibility of an organization’s risks with an assessment based on multiplying the likelihood that a risk will occur by its impact on the organization.
Risks can also generally be classified into high risks, medium risks, and lows risks. A high level risk has a higher chance of occurrence and can cause significant damage to the organization. A Medium risk has a 50% chance to occur and will cause damage but not too high or low. A low risk has low chances of occurring and will not cause any severe damage. However, in some cases, the chances of the risk appearing might be low, but it could cause severe damage. A risk assessment matrix depicts a visual form of risk assessment with highest level of risks at one end, the lowest level on the other, and medium risks in the middle. It often uses color-coding to represent different levels of risks to identify where to give more attention.
A risk assessment matrix contains a set of values for a risk’s probability and likelihood. The following image depicts a 3x3 risk matrix that has 3 levels of likelihood and 3 levels of severity.
A GRC platform like VComply can help you perform risk management and design internal controls that keep your organization compliant. VComply provides an uncomplicated way for you to manage compliance and risk, allowing you to assign controls and track them through an intuitive interface.
Cyber threats have grown from being plausible to probable. With organizations becoming more dependent on the internet, social media, and digitization, exposure to cyber risk has also increased manifold. Today, cyber security is among the top priorities of organizations world-wide simply because a cyber-attack can leave your organization in a dilapidated state – untethered from information systems and unable to provide services, owning a handful of compromised data, and staring at massive reputation loss.
To discover the big picture, consider some recent statistics. IBM reports that the global average cost of a data breach in 2020 was $3.86M. For the healthcare industry, the average cost is almost double, $7.13M. Concurrently, HIPAA Journal reported that 9.7M health records were compromised in September 2020 alone. But it’s not just big businesses that are facing the brunt of cyber breaches, 43% of cyber-attacks target small and medium businesses, notes Fundera.
With cybercrime growing at a compounding rate – 300-600% in recent months – cyber risk positions itself as the biggest challenge to organizations around the globe. Here’s a primer on cyber risk and your organization.
Cyber risk refers to the risk associated with “financial loss, disruption or damage to the reputation of an organization from failure, unauthorized or erroneous use of its information systems,” as per PWC. However, it includes the “the potential of loss or harm related to technical infrastructure or the use of technology within an organization,” according to RSA.
Cyber risk can materialize in varied forms. Here are some examples of cyber risk:
Cyber risks can be classified according to intent and source:
It is worth noting that the classification of cyber risks according to intent and source may not determine the negative impact they have on your organization. For instance, reports have it that 52% of data security breaches boil down to human error and system failure. Another report indicates that 95% of cybersecurity breaches have their source in human error.
The impact of cyber risk can be divided into a few categories:
The cost of protection is also something that can be added to this list. Building safer information and networking systems takes money and requires the use of vetted software and hardware. The ongoing management of these systems and their maintenance also add to the costs.
In today’s digital age, you cannot avoid exposing yourself to some amount of cyber risk. You cannot avoid digitalization or digital transformation just because you want to avoid cyber risks. It can affect your business growth, revenue expansion, and market consolidation.
Hence, the goal is to navigate cyber risk well.
Firstly, you need to know what your assets are. And what you are trying to protect from intentional/ unintentional cyber risks:
Then, you need to understand what cyber threats you may face, and which assets may come under fire. Cyber threats are not the same as cyber risks. A threat is an event that can exploit a point of vulnerability to damage an asset. When you have linked cyber threats to your assets, you know what cyber risks you have on hand.
With this information ready, you can then proceed to drafting a cyber risk appetite statement. Defining your cyber risk appetite gives you clarity on many fronts:
Cyber risk management is an ongoing process that can be broken down into a few key steps:
Identify the risks: Note your assets, threats, and vulnerabilities. For instance, you may have a weak technological infrastructure with employees working from home on personal devices, and this could lead to company data being more vulnerable. Here are some possible avenues of cyber risk:
Assess the risks: At this stage, you need to analyze the risks in terms of their likelihood and severity. Based on that you can forecast what the impact of the risk may be.
Evaluate and prioritize the risks: This becomes easy if you have a well-defined risk appetite statement. You can begin to answer questions such as:
Respond to the risks: You can modify the impact of a risk by adopting a corrective control. For instance, you can enforce multi-factor authentication for more secure logins, deploy company apps to isolate sensitive data, and adopt a policy for patch/ update management. Exploring the 20 CIS controls can prove to be vital.
Here are some practical ways to reduce cyber risks:
After treating your risks with controls, you decide to tolerate some cyber risks, terminate others, and transfer the rest to a third party.
Your cyber risk management efforts work best when they tie in with your organization’s risk management framework. Moreover, you should strive for a three-pronged approach of ‘cyber risk assessment’, ‘cyber risk management’ and ‘cyber risk monitoring’. Whether it is enforcement, accountability or the aspect of bringing senior leadership into the game, you can best integrate cyber risk management with your GRC strategy when you have a risk management platform like VComply.
With VComply, you can set in motion cyber risk management lifecycle, invite collaborators to evaluate risks, establish tolerance levels, monitor your risks, assign implement controls to address risks, delegate ownership, and escalate failures, setup alerts and more. This gives you the means to safeguard your organization against internal and external cyber threats in real-time.
Risks are inevitable in business. Businesses must reduce their exposure to risks and find ways to mitigate them to remain competitive in business. Identification and acknowledgement of risks that affect the operations, profitability, security, or reputation of the business is the first step. Developing strategies to mitigate these risks is the next and the most essential step! Risk mitigation is an important step in risk management that includes identifying the risk, assessing the risk, and mitigating the risk.
Risk mitigation can be defined as taking steps to reduce or minimize risks. When you devise a strategy for reducing prospective risks and working with an action plan, it is important that you choose a strategy that relates to your company’s profile and nature of business.
Here's why risk mitigation is important:
- A robust risk mitigation plan helps establish procedures to avoid risks, minimize risks, or reduce the impact of the risks on organizations.
- It guides organizations on how they can bear and control risks. This helps a business in achieving its objectives.
- The ability to understand and control risks makes an organization more confident and helps in making the right business decisions.
- It increases the stability of the organization and reduces its legal liability.
- It protects people involved and company from any potential harm.
Let's take a close look at different strategies for mitigating risks:
Accepting a risk does not reduce the impact of it on the organization. However, risk acceptance is considered as a valid option. Accepting risks involve identifying and analyzing risks and bringing these risks into the attention of stakeholders so that everyone involved are aware of the risks and its consequences. The most common reason for accepting a risk is that the cost of mitigation options might outweigh the benefit.
This is exactly the opposite of the accepting risk. If the risk poses unwanted consequences, the organization chooses to avoid the action that leads to the exposure of the risk. Not starting a project that involves high unwanted risks avoids the risk completely.
Risk transfer is the involvement of handing over the risk or a part of risk to a third-party. A conventional means to transfer risk is to outsource some services to a third-party. Many organizations outsource payroll, recruitment services to third party. It might involve some drawbacks and take out some control from your organization.
Businesses use this tactic most often in risk mitigation. It may include reducing the probability of the occurrence of the risk, or the severity of the consequences of the risk. If the organization cannot reduce the occurrence of the risk, then it needs to implement controls. Implementing controls should aim at reducing the chances of the risk occurring or finding out the cause for the risks and try avoiding it. Implementing appropriate controls depends on an organization’s decision making process and the nature of the business. One typical example for reducing a type of risk could be using a component tested and available in the market than subcontracting to create the same to a third-party.
Risk management and mitigation process consists of identifying, assessing and mitigating risks. There are different steps involved in creating a risk mitigation plan. These include:
All the risks must be noted distinctively. This includes every risk big or small, that may harm the organization. The identified risk can be added to a risk register.
Define and describe a risk. Describe the intensity of the risk and the areas it will impact.
All risks that are identified and described must be forwarded to respective entities to take action on mitigating them. The person handling the individual risk is answerable to the management about it.
There are different types of risks, such as business risks and non-business risks. You can also categorize risks as small risks, medium risks, and high risks. Then, there are risks which you can afford to take and those that should be avoided.
This is the main part of risk mitigation, which involves taking actions to minimize risks. Appropriate actions should be taken to control risks and dodge them when they come up, so they don't become a barrier in achieving business objectives.
Here are some ways businesses can make their risk mitigation strategies more effective:
There should be complete transparency in an entire organization. Even minor miscommunication or misinformation could lead to big problems. Therefore, its important that each step is clearly discussed and known to each stakeholder to mitigate risks.
Many businesses have experts in their team who deal with risks tactfully and also know the consequences if risks occur. Businesses should appoint such experts to oversee risk mitigation in an organization, and also hold team members responsible for each type of risk.
Regular reporting provides a clear picture of the situation and the actions that need to be taken. Thus, management should encourage all teams to regularly report on the risks they're managing and controlling.
Evaluation of risks helps you identify which risks might occur, and when and where. This helps you create better risk management plans.
Each stakeholder must have one common goal: to cut down risks that come their way. No personal interest should be involved. This helps keep everyone on the same page and upholds the business ethics and interests.
While risks are an inherent part of every business, risk mitigation helps businesses minimize the impact of certain risks, while acknowledging and accepting others.
VComply provides an effective way for businesses to track and mitigate risk. VComply helps manage and automate the risk management processes such as risk assessment and risk treatment. The best risk mitigation strategies involve maintaining a risk register, regular reporting, teamwork, and planning.
Etymologically, the word resilience has roots in the Latin term resiliere, which means ‘to rebound’. In similar vein, operational resilience describes an organization’ stability to cope with change or misfortune. The ongoing global pandemic, COVID 19 is an extreme form of misfortune, but its impact has been so universal that it has laid bare each organization’s level of operational resilience and sparked renewed interest in the topic.
Stress, threats, potential failures, disruptions, uncertainty, and change are part of the life of an organization, but one that is operationally resilient has the wherewithal to maneuver through it all. From climate change, power grid black outs, and cyber-attacks to a tainted image on social media and demand-supply disruptions, there are numerous factors that can cause an organization to buckle and crack. A resilient organization has the frameworks and mechanisms to bounce back when dealt the unexpected.
Operational resilience, however, goes further than an organization simply maintaining business continuity or managing risk.
Here are two helpful definitions:
Gartner: Operational resilience is a set of techniques that allow people, processes, and informational systems to adapt to changing patterns. It is the ability to alter operations in the face of changing business conditions. Operationally resilient enterprises have the organizational competencies to ramp up or slow down operations in a way that provides a competitive edge and enables quick and local process modification.
PwC: We define operational resilience as “an organization’s ability to protect and sustain the core business services that are key for its clients, both during business as usual and when experiencing operational stress or disruption.”
The operational resilience definition offered by Gartner places a lot of emphasis on ‘techniques’, ‘abilities’, and ‘competencies’. PwC too focusses on ‘ability’ but brings the end goal in picture, that is, service of the ‘client’.
This article will elaborate more on these themes, while also providing some operational resilience examples.
To work within a sound operational resilience framework means to consider risks in a holistic manner. It involves moving away from a vertical and siloed approach to a horizontal and organization-wide approach. This way you aren’t left facing collapsing dominos when one segment of your operations stalls. Similarly, key to the word resilience is the aspect of bouncing back and if your operational resilience strategy focuses on avoiding disruptions only, it is inadequate. Operational resilience is a trait by which your organization can get back to everyday business once a disruption occurs too!
Today, amid the pandemic, digital adoption is what has kept many businesses running and building a layer of digital resilience can help you put your best foot forward. With more and more touchpoints in the customer journey being digitized, it becomes important to live up to the customer expectation of having always-on services. Issues like server outages can dampen customer confidence.
Digital processes run on data as a fuel and your operations will be only as good as the quality of data you possess. Data resiliency includes aspects like restoring compromised data, preventing data loss, and establishing a sync point in case of a snag.
Alongside digitalization and increased data comes the need for cyber operational resilience. For instance, on 5 March 2020 the US Power Utilities were the subject of a cyberattack that used firewall vulnerabilities to cause ‘blindspots’. The system was resilient enough that actual flow of electricity was not affected. However, this incident shines light on present-day practices that hamper organizational resilience. These include using sensitive apps over home Wi-Fi, storing passwords on home devices, and limited awareness about data privacy.
When an organization is in its nascent stages, everything revolves around satisfying the client. At such times, it is quite clear what the firm’s key business processes are, which add direct value to the client. However, as an organization scales, processes become more abstract and even at the C-level, one is not dealing with the client’s needs and aspirations directly, but with other contingencies. While it is required that, for instance, the CIO, COO, and CEO take up different responsibilities, resilience is built when these are ordered to the client’s needs.
This approach makes it easier to identify key products and services, meaning that business continuity planning becomes more strategic and secure when the client is at the center. The goal of a client-centric operational resilience strategy must be to uninterruptedly deliver critical operations, even amidst disruptions.
At a certain level, your organization is only as good as your employees. Business staff man several key processes, without which products and services would never reach the client. Factors like employee attrition and wages are perennial issues that threaten business continuity, and hence operational resilience. But in the wake of the pandemic, newer issues such as employee wellness have surfaced. In an increasingly remote-first work environment, HR teams have the tricky task of accepting work from home’s olive branch of business continuity, while knowing that prolonged isolation is a deadly threat to creativity, collaboration, and long-term goals.
Whether you have an operational resilience manager or not, possessing a framework for managing third-party relationships that are interwoven with critical operations is a must. This is another way of saying that the client shouldn’t be at the receiving end of issues related to sourcing and other external dependencies. Achieving this includes performing due diligence and risk assessment according to your standards for operational resilience before entering into an agreement.
GRC is integral to operational resilience – and not just because organizations are increasingly coming under the scrutiny of regulatory authorities! A good operational resilience framework includes having a governance structure that can respond to disruptions. Ongoing risk assessment too is crucial to weeding out vulnerabilities and avoiding threats. As mentioned earlier, being resilient means moving away from silos and being more holistic and here, GRC software serves aptly as operational resilience technology.
Solutions like VComply ensure you have a better way to run your business. VComply is a comprehensive platform you can use to govern risks, stay compliant, and implement an operational resilience strategy in a way that you cannot with spreadsheets and binders. With automated reports, integrated workflows, data centralization and more, you can more reliably work towards making your business‘ disruption-proof’.
With a better understanding of what operational resilience is, proceed to define what it means in the context of your organization and grow your business strategically!