Operational risk, internal and permanent control

Advisory

Your challenges

The decree of November 3, 2014 on internal control of financial institutions requires the implementation of a permanent control system (1st and 2nd level) which is an essential brick of internal control and a major issue of securing and competitiveness of activities for financial institutions.

Permanent control has two levels:

Level 1 represents all controls integrated into operational processes, IT systems (manual and automated controls) and self-checks.
Level 2 corresponds to controls carried out after the fact, at a predefined or random frequency, by entities that are not operationally involved and are independent.

The issues for institutions are to:

Define the responsibilities of the two levels of defense so as to guarantee effective permanent control.
To have shared guidelines and tools, and to rely on an exemplary general management.
Review and challenge the permanent control system annually.

Our offers

To assist its clients in reviewing their permanent control system and thus enable them to control all their risks, FINEGAN offers to :

Mapping activities, processes, risks and controls.
Review the coverage of all activities and risks: No gap

Adapt the organization to the requirements of permanent control segmentation:
o Definition of control objectives specific to each level: No overlap
o Distribution of roles: RACI, independence of CN1 vs. CN2.
Establish governance at all levels to allow for global monitoring of permanent control: group and business line monitoring committees, risk homeostasis.
Reinforce the “risk” culture within all teams: training, reporting of alerts with dedicated action plans.

Our support

Our teams assist our clients in defining, according to the organization, the responsibilities of the two levels of defense (CN1 and CN2) in order to guarantee an effective permanent control.

We are also able to define the reference systems (activity, processes, risks, controls) and to assist our clients in the choice of shared tools to carry out controls and collect control data, as well as to review and challenge the permanent control system annually.

In addition to mastering the issues related to permanent control, the expertise of our teams in transformation and project management includes both organizational and IT aspects.

They trust us

A major French bank

Review of a permanent control system

Context: Support of a large banking group in the context of an ECB remediation aimed at improving the 1st and 2nd level permanent control system.
Our mission: To drive the transformation of the permanent control system at the Group and entity levels in order to establish a mapping of the control repository in line with the risks (Basel II) and the regulatory requirements (review and harmonization of controls), then of the processes and activities. The implementation of a solution based on Artificial Intelligence (AI) and semantic analysis has largely contributed to the alignment of repositories.
Our added value: Our ability to manage a program requiring multiple business expertises and to propose innovative solutions.

A French banking group

Risk and Control Self Assessment (RCSA)

Context: After having reviewed and deployed its control system, this banking group wished to ensure the quality of its system and the review methodology of this system.
Our mission: Deployment of a risk and control self-assessment methodology (RCSA) after having defined the end-to-end processes and operational governance. This implementation also required upgrading the normative corpus and ensuring its operational declination to then train the users.
Our added value : Our knowledge of the entire value chain that governs permanent control systems, i.e. the design of controls, their implementation and the verification of their effectiveness.

A French bank and insurance company

Reorganization of a control system

Context: Following the merger of two entities, the bancassurer mandated us to support the business lines in the strategy of reorganization and integration of the control system.
Our mission: After making the business processes (management acts...) more reliable and secure, homogenization of the control system with a common normative framework for both entities, requiring the alignment of practices by reinforcing controls on the aspects of "quality of service" and redesigning the risk mapping.
Our added value: Our knowledge of the insurance business combined with our expertise in terms of risk mapping and control systems.

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