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Compliance Risk Self Assessment Model. Compliance Risk - Definition. The risk to earnings or capital arising from violations of, or nonconformance with laws, rules, regulations, prescribed practices, or ethical standards.
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Compliance Risk - Definition • The risk to earnings or capital arising from violations of, or nonconformance with laws, rules, regulations, prescribed practices, or ethical standards. • Compliance risk also arises in situations where the laws or rules governing certain bank products or activities of the bank's clients may be ambiguous or untested.
Compliance Risk Assessment Phases • Bank should periodically assess Compliance risk impact • Bank should measure the magnitude of potential loss; • Reputation • Regulatory • Operational • Legal / Error • There are three main phases to assess the compliance risk • Phase 1: Data Collection • Phase 2: Compliance Analysis • Phase 3: Communicating Compliance Risk
Phase 1 : Data Collection • Step One: Products and Services • Make a list of all products and related services that are offered. • Step Two: Systems and Controls • List all types of Controls related to each product in questionnaire format • Interview Department Management to identify controls
Phase 2: Compliance Analysis • Compliance convert business response to: • Regulatory Risk • Reputation Risk • Operational Risk • Probability of Error Risk • Compliance to prepare Inherent & Residual Risks levels
Phase 3 :Communicating Compliance Risk • Step One: Align with Business • Compliance will call for meeting with Business head • Compliance will present their analysis and identify Compliance High Risk issues • Business to demonstrate probability of risk change over next 12 months • Document Corrective actions plan • Step Two: Escalation Process • Compliance will escalate Compliance issues with increasing risk level.
Outcome • What are the biggest compliance risk facing your bank/division/department • What about the next three years • Risk definition / description • Current controls