Governance & Risk Management at the Central Bank of Malta Banking & Finance Workshop Anthony P Cortis Director Statistics & Risk Management Directorate April 2012 Overview What is governance Risk management framework 2 Risk Management Philosophy ► The Board of Directors is ultimately responsibility for ensuring that the Bank’s risks are being properly identified, monitored and controlled. ► However the management of risks rest with the line managers and is an integral part of the general day-to-day management task. ► The Bank supplements its risk management by employing an active committee structure with participation which includes members who are not directly responsible for the process. This greatly improves the likelihood that all aspects (including any risk element) of an issue or policy are adequately considered before decisions are made. 4 Risk Management Framework CORPORATE GOVERNANCE MONITOR AND REPORT RISK RECOGNISE AND MANAGE RISK Tone at the top Board of Directors Integrated Risk Management Three lines of defence model Policy / Management Committee Audit Committee Heads / Directors Risk Mgt Committee 1 2 3 functions owning and managing risks on a day to day basis functions promoting common risk management methodologies and consolidating risk reporting functions providing independent assurance on the effectiveness of the governance, risk and control environment Line Management Risk Management Internal Audit Governors 5 Organisational Structure Governors Director General Financial Policy & Special Projects Financial Stability & Information Systems Directorate Market Operations Directorate Financial Services Directorate Governors’ Office Internal Audit Dept Economics & Research Dept Comm & Legal Dept EU & Int Relationship Dept Corporate Services Directorate Statistics & Risk Management Directorate Strategy, Policy & Risk Management Department Organisational structures responsible for risk assessment, monitoring and control (but not directly for risk management) are Internal Audit Dept and Strategy, Policy & Risk Management Dept 6 Processes aimed at achieving better risk management Business Process Policies & Procedures Risk Mapping Business Continuity Planning Information Security Framework Support & Awareness Identifying all business processes within the Bank 8 Processes aimed at achieving better risk management Business Process Policies & Procedures Risk Mapping Business Continuity Planning Information Security Framework Support & Awareness Ensuring that all Offices have in place sound policies and operational procedures for every business process under their responsibility as a primary means to mitigate risk; 9 Policies & Procedures ► Good corporate governance dictates that responsibilities, delegations of authority, operational procedures and control processes are documented and disseminated to staff. ► Opportunity to: Review and update the Policies & Procedures of all processes Understand the inherent risks that are present in the processes Evaluate all the existing controls Recommend new controls to management to mitigate such risks in conjunction with Internal Audit Office Information Security Framework ► SPRD co-ordinates the review and maintenance of the Bank’s Policies & Procedures with Office Managers. Support & Awareness ► Policies & Procedures are approved by the PAC/MC. Business Process Policies & Procedures Risk Mapping Business Continuity Planning 11 Processes aimed at achieving better risk management Business Process Policies & Procedures Risk Mapping Business Continuity Planning Information Security Framework Support & Awareness Systematically identifying and assessing risks and controls across business processes in the Bank, thus constructing the Bank’s Risk Matrix for use by management; 12 Risk Mapping Business Process ► It is crucial for any organisation to have a sound understanding of its business, the nature of its risks and its strategic direction. This provides the foundation for the sound management of any organisation. ► SPRD co-ordinates the systematic identification and assessment of risks across all the business processes. ► All business processes are assessed and assigned an inherent risk value. This is done in consultation with Office Managers and Internal Audit Department. Policies & Procedures Risk Mapping Business Continuity Planning Information Security Framework Support & Awareness 13 Risk Mapping ► All high risk processes undergo a further detailed risk assessment. ► The risk assessment identifies what the specific risks of the business processes are, and it evaluates how these risks are being controlled and monitored. Business Continuity Planning ► Each specific risk identified is given a residual risk value. Information Security Framework ► The risk assessment is sign-off by the Office / Senior Managers. ► The risk assessment is loaded in the Risk Matrix database. Business Process Policies & Procedures Risk Mapping Support & Awareness 14 Risk Mapping Business Process Policies & Procedures ► ► It reinforces accountability and ownership of risk and control by the business units. It helps to focus management’s attention on the high risk business processes. Risk Mapping ► Management has a clearer understanding of the risks that the Bank is faced with, and how these are being controlled. ► Management can introduce new controls and monitors so that risks are further mitigated. ► The Audit Committee monitors the progress achieved in the Risk Matrix. Business Continuity Planning Information Security Framework Support & Awareness 15 ORM Framework Operational Risk Taxonomy Risk root causes: Risk events: Risk impacts: • People • Systems •Governance & Business Processes • External events Fraud, Incidents, Disasters, Attacks, Errors & Failures, Infrastructure disruptions • Business • Reputational • Financial Identification of enabling factors of risk events Supports analysis of observable events / incidents Allows management to review and manage risks based on intuitive categories of impact Risk treatment measures / controls 16 6 ORM Framework 1 Business Area Board of Directors identifies and assesses risks through the Audit Committee reviews the status of the Bank’s operational risk profile proposes action plans as necessary approves implementation of action plans accepts risks upon the recommendations received by ORC and endorsed by PC 2 3 SPRD Director/Heads of Business Area coordinates, supports and reviews risk assessment review risk report for business area agree on action plans consolidates reports 4 5 Policy Advisory Committee discusses business area risk map and proposed actions plans approves action plans / or recommends to Board Operational Risk Committee discusses business area risk map and proposed actions plans approves action plans / or recommends to Policy Committee 17 Processes aimed at achieving better risk management Business Process Policies & Procedures Risk Mapping Business Continuity Planning Information Security Framework Support & Awareness Ensuring that Offices are prepared to deal with uncertainties, so that the continuity of critical business processes is safeguarded; 18 Business Continuity Management Business Process ► Good corporate governance lays down that an organisation needs to ensure that its critical business processes are neither disrupted nor adversely affected by disasters and problems, both internal and external. ► SPRD co-ordinates a project through which the Bank is developing, testing and maintaining an adequate Business Continuity Plan to provide continuity of business in the event of disruption. Policies & Procedures Risk Mapping Business Continuity Planning Information Security Framework Support & Awareness 19 Processes aimed at achieving better risk management Initiatives aimed at achieving better risk management: Business Process Policies & Procedures Risk Mapping Business Continuity Planning Information Security Framework Support & Awareness Ensuring that the confidentiality, integrity and availability of information is safeguarded through the implementation of an effective Information Security Management programme; 22 Strategy, Policy & Risk Management Department Initiatives aimed at achieving better risk management: Business Process Policies & Procedures Risk Mapping Business Continuity Planning Information Security Framework Support & Awareness Providing technical support and risk management awareness through ad hoc risk assessments and training. 24 Provide Risk Management Support Business Process ► Policies & Procedures Risk Mapping ► Business Continuity Planning Participation in Bank committees Health & Safety Committee Carry out ad hoc risk assessments in new areas of operations in existing areas of operation where the environment is changing (because of laws, systems, procedures, staff, etc) Information Security Framework ► Carry out Risk Management awareness with staff Support & Awareness 25 Risk Management at the Central Bank of Malta Questions? cortisa@centralbankmalta.org