Erwin Boeren 270002C43V ERWIN.BOEREN@NL.IBM.COM | | Tags:  compliance grc governance manufacturing smarter energy&utilities openpages risk enterprise deloitte project | 0 Comments | 1,804 Visits
Smarter Project Risk
Last week I came across project risk, and not for the first time! So, time to spend some words on this topic.
Especially organizations in Energy&Utilities and Manufacturing have huge risks in their assets and in their projects. You think you have all risks identified through the standard risk identification process and you just missed that elephant?! This might impact your yearly financial result or worse!
This is why more and more clients start to look at Project Risk methodologies. My client happened to use the PMBOK methodology. In this methodology you consider standard project phases including standard risks and controls. This is great, since you have most of the standard risks covered. But what about that risk that is just not standard? This is where gate reviews will help you. These gate reviews are held after every project phase. Each gate review contains questions used to identify risks, holds monitoring methodologies to check status and behavior and contains audit like activities. Key element here is that all findings roll up to top level so no significant risk can be missed.
all works for what we call manageable risks, but what about risks that you
cannot manage? How will you anticipate on this? Well these risks can be covered
by sensitivity analysis, simulations and business continuity management.
Especially sensitivity analysis and business continuity analysis will help you.
For simulations you will need data, and a significant amount of data. Only in
case you have many similar projects running in a regular cycle you will be able
to generate enough risk identifications and losses to be able to make a sensible
Now the system is in place, and now we are in control? Wrong! This is where the real work starts. How do I get my organization to adopt risk in her daily business? How do I get input with the right quality? How do I make everyone a risk manager? This takes time and effort. Guide your people in how to make the assessments and make them part of it. Give them back where they contributed to, and make their life easier. That is what we call Smarter Risk.
IBM OpenPages and Deloitte have put together a Risk Methodology for project risk where all these technologic and organizational aspects come together and can be integrated in your enterprise risk platform.
Blog post by Erwin Boeren
Senior Governance, Risk & Compliance specialist IBM
Twitter : http
Erwin Boeren 270002C43V ERWIN.BOEREN@NL.IBM.COM | | Tags:  risk operational grc compliance ibm openpages solvency governance | 0 Comments | 1,628 Visits
Solvency II and the need for Operational Risk
Blog post from Erwin Boeren, Governance Risk &
Blog post from Erwin Boeren, Governance Risk &
Liz Andrews 2700041WEU firstname.lastname@example.org | | Tags:  grc risk openpages | 0 Comments | 1,546 Visits
This is the first in a series of four blog posts where we will present risk and compliance speaker and thought leader, Michael Rasmussen's, GRC maturity model. For more insightful information on GRC and to exchange ideas with risk and finance colleagues, come see us in Orlando at Vision 2012.
Success in today’s dynamic business environment requires organizations to integrate, build and support business processes with an enterprise view of governance, risk management and compliance (GRC). Without an integrated view of risk and compliance, the scattered and nonintegrated approaches of the past fail and expose the business to unanticipated risk.
In a mature GRC program, the organization has an integrated process, information and technology architecture that provides visibility across risk and compliance domains. It offers an integrated approach for business managers and executives to leverage GRC data for risk-aware decision-making and resource allocation.
Inevitable Failure: Managing GRC in Silos
The multifaceted risk environment
Risk to the business is like the hydra in mythology — organizations combat risk, only to find more risk springing up to threaten them. Executives are constantly reacting to risk appearing around them and fail to actively manage and understand the interrelationship of risk across the enterprise.
The dynamic and global nature of business is particularly challenging to risk management. As organizations expand operations and business relationships (e.g., vendors, supply chain, outsourcers, service providers, consultants and staffing) their risk profile grows exponentially. Organizations need to stay on top of their game by monitoring risk to their business internally (e.g., strategy, processes and internal controls) and externally (e.g., competitive, economic, political, legal and geographic environments) to stay competitive in today’s market. What may seem an insignificant risk in one area can have profound impact on others.
Organizations are increasingly aware of the critical need to link risk management and corporate performance management. To manage corporate performance, the organizations must understand risk and make risk-informed business decisions.
In the area of regulatory risk, organizations face an expanding regulatory environment with rapidly increasing requirements that burden the business. Organizations face expanding regulations, increased fines and sanctions, and aggressive regulators and prosecutors around the world. Reputation and brand protection is also a significant compliance and risk management issue in a global environment.
Isolated risk and compliance initiatives introduce greater risk
Managing GRC activities in disconnected silos leads the organization to inevitable failure. Reactive, document-centric and manual processes for GRC fail to actively manage risk in the context of business strategy and performance, and leave the organization blind to intricate relationships of risk across the business. Siloed GRC initiatives never see the big picture and fail to put GRC in the context of business strategy, objectives and performance, resulting in complexity, redundancy and failure. The organization is not thinking about how GRC processes and controls can be designed to meet a range of risk and compliance needs. An ad hoc approach to GRC results in poor visibility across the organization and its control environment, because there is no framework or architecture for managing risk and compliance as an integrated part of business. When the organization approaches risk in scattered silos that do not collaborate with each other, there is no possibility to be intelligent about risk and understand its impact on the organization.
A nonintegrated approach to GRC impacts business performance and how it is managed and executed, resulting in:
The pain organizations have expressed
Siloed GRC processes, though effective in their own silos, are ineffective at an aggregate level, as the organization does not have a complete view of GRC in the context of the business. Corporate Integrity finds organizations that lack a collaborative, integrated and enterprise approach to GRC have:
Continue on to Part II in this series: GRC Maturity — Measuring a New Paradigm for Risk and Compliance
Liz Andrews 2700041WEU email@example.com | | Tags:  openpages grc risk | 0 Comments | 1,532 Visits
This is the second in a series of four blog posts where we present risk and compliance speaker and thought leader, Michael Rasmussen's, GRC maturity model. For more insightful information on GRC and to exchange ideas with risk and finance colleagues, come see us in Orlando at Vision 2012.
GRC Maturity — Measuring a New Paradigm for Risk and Compliance
Lacking an integrated view of GRC results in business processes, partners, employees and systems that behave like leaves blowing in the wind. Modern business requires a new paradigm for tackling risk and compliance issues across the enterprise. No longer can organizations afford to focus on single risk and compliance issues as unrelated projects; nor can they allow software Band-Aids that are not integrated with the business to masquerade as GRC. A targeted strategy addressing GRC through common processes, information and technology gets to the root of the problem.
With changing and diverse risks bearing down on the organization, there is a clear need to tackle the problem at its root and develop a mature approach to GRC. Instead of treating each risk and compliance issue as an individual problem, organizations need to define a common process, information and technology architecture to manage GRC across the range of issues.
To address these issues, leading organizations have adopted a common framework, information architecture and shared processes to effectively manage risk and compliance, enable risk-aware decision-making, increase efficiencies, and be agile in response to the needs of a dynamic business environment.
The questions organizations must ask:
A well-defined GRC environment will not only do risk assessment and modeling, but will also deliver definition, communication and training on risk-taking and accountability. The organization must map the interrelationship of risks to controls, policies, enterprise assets (e.g., business process, employees, relationships, physical assets and logical assets), and incidents to business strategy, objectives and corporate performance.
Mature GRC delivers better business outcomes because of stronger integrated information, which will:
Architect integrated GRC systems and processes
A properly defined GRC architecture is built upon common process, information and technology components that are adaptive to a dynamic business environment and integrate with critical enterprise applications. No longer is risk and compliance about an annual audit; it now involves continuous monitoring in an ever-changing environment. GRC has to be sustainable as an ongoing and integrated part of business processes. A successful and mature GRC strategy has a symbiotic influence on the variety of business stakeholder roles and their common requirements.
Organizations need to be intelligent about what processes and technologies they deploy. The goal is to make an effective decision once, and comply with many regulations, manage a range of risks and maximize value from the convergence of technology, people and process. A sustainable approach to GRC results in an organization looking to the future and mitigating risk in the course of business, as opposed to putting out fires by reacting to risk and control issues as they arise.
Mature GRC enables the organization to understand performance in the context of risk and compliance. It achieves the definition of GRC, which is “a capability that enables an organization to reliably achieve objectives [GOVERNANCE] while addressing uncertainty [RISK MANAGEMENT] and acting with integrity [COMPLIANCE].” Effective and mature GRC delivers:
Continue on to Part III in this series: Five Stages of GRC Maturity
Liz Andrews 2700041WEU firstname.lastname@example.org | | Tags:  risk openpages grc | 0 Comments | 1,526 Visits
This is the third in a series of four blog posts where we will present risk and compliance speaker and thought leader, Michael Rasmussen's, GRC maturity model. For more insightful information on GRC and to exchange ideas with risk and finance colleagues, come see us in Orlando at Vision 2012.
Five Stages of GRC Maturity
Mature GRC is a seamless part of governance and operations. It requires the organization to take a top-down view of risk, led by the executives and the board, and made part of the fabric of business, not an unattached layer of oversight. It also involves bottom-up participation where business functions at all levels identify and monitor uncertainty and the impact of risk.
Corporate Integrity has developed the GRC Maturity Model to articulate an organization’s maturity in GRC processes.
1: Ad Hoc/Unaware — Department-Level Maturity
Characteristics of this GRC stage are:
Organizations in the Ad Hoc/Unaware GRC stage answer many of the following questions affirmatively:
2: Fragmented — Department Level Maturity
Characteristics of the Fragmented GRC stage are:
Organizations in the Integrated GRC stage answer many of the following questions affirmatively:
3: Integrated — Department Level Maturity
Characteristics of the Integrated GRC stage are:
Organizations in the Integrated GRC stage answer many of the following questions affirmatively:
4: Aligned — Enterprise GRC Maturity
Characteristics of the Aligned GRC stage are:
Organizations in the Aligned GRC stage answer many of the following questions affirmatively:
5: Optimized — Enterprise GRC Maturity
Characteristics of the Optimized GRC stage are:
Organizations in the Optimized GRC stage answer many of the following questions affirmatively:
Come back next week to view the final post in this series: Getting to the Head of the Class: Advancing Your Organizations GRC Maturity
Erwin Boeren 270002C43V ERWIN.BOEREN@NL.IBM.COM | | Tags:  analytics grc busness management openpages ibm erwin boeren performance risk | 0 Comments | 1,522 Visits
Last year IBM acquired OpenPages as a strategic move into the area of Governance, Risk and Compliance. The lasest announcement to acquire Algorithmics (quantitative risk management) shows the continuous commitment of IBM in the GRC market. GRC software will integrate into the Business Analytics Software group, the area where the former acquisitions like Cognos, SPSS and Clarity systems already resides.
Now that Risk Management is evolving, more and more organizations are starting an enterprise approach to risk management. And this is where I see the need for Risk and Performance Management convergence.
In past Risk Management implementations I see that a major portion of time and budget was spent on Risk Reporting and Dashboarding. Especially the need for self service reporting, where users can ad hoc create their own risk reports, is growing. We do not want to wait in the queue waiting for our report to be created. 2 days later you missed the opportunity to respond and the loss is there.
With this self service capability the question automatically pops up 'can I trust my data'. And now we are back in the area of data governance. This is exactly where the area of Performance Management is today.
Apart from these reporting and dashboarding capabilities Enterprise Risk Management means alignment of risks and controls to the strategic initiatives of the organization. What will prevent me from reaching my business goals? Isn't this defined as a risk? And how will we prevent this from happening? Wasn't that defined as a control?
Even more interesting are questions like, 'What if I was able to perform risk scenario planning?', 'What if I could predict risks from happening?' or 'What is the correlation between the risks that have materialized?'.
And there is the proof that Risk Management and Performance Management have lots in common and should be integrated. Lets call it Business Analytics.
Governance, Risk & Compliance Leader
IBM IOT Southwest Europe
Erwin Boeren 270002C43V ERWIN.BOEREN@NL.IBM.COM | | Tags:  openpages grc ipad solvency reporting | 0 Comments | 1,455 Visits
With Cognos 10.1.1 released you must have noticed the ability of having your reports and dashboards on mobile devices like iPad and iPhone.
With these mobile capabilities CROs (Chief Risk Officers) will now have the ability to measure risk from their mobile devices. For volatile risk areas like Market and Credit Risk this can make a huge difference.
IBM developed a risk monitoring system for CROs where one single version of the truth is provided of different risk areas like Credit Risk, Market Risk, Counterparty Credit Risk, Liquidity Risk, Basel II, Solvency II and Operational Risk. Not only does a CRO have the ability to monitor all these risk areas but he can also monitor the correlation between those risk areas and he is able to respond immediately to changes. Responses can immediately be formulated in the integrated social media platform.
One version of the truth and guaranteed quality of your data is simple to say but how do you govern this? This is where IBMs investment in data models starts to pay off. Since decades IBM develops and maintains data models for financial services including out of the box technical and business definitions. This enables organizations to come to one definition of risk over the entire organization. Taking definitions centrally will add value in the process of taking down the silod approach we spoke about in earlier articles. It will also help you in the accountability process of the business. Finally it is the business that should own the business definitions.
As discussed in our previous published blog (The convergence of GRC and Performance Management) Business Analytics capabilities like risk forecasting, risk adjusted profitability calculations, scenario planning and predictive risk analysis are part of this risk monitoring system called FIRM (Finance Integrated Risk Management).
The new regulation for Insurance companies, Solvency II requires organizations to plan their risk assessments and capital requirements 2 to 5 years ahead and to reflect impact on financial positions when a risk materializes. All this means that an integrated approach to risk management is a must. In next blogs we will go deeper into the Solvency II regulation.
Richard Steinberg 270004HRBG email@example.com | | Tags:  risk openpages dodd-frank grc sec whistleblowing | 0 Comments | 1,286 Visits
The SEC’s final rules implementing Dodd-Frank’s whistle blowing provisions failed to remove angst among compliance officers and general counsels. While there are some incentives for potential whistleblowers to first report alleged misconduct via internal reporting channels, there’s no requirement to do so – and many are concerned the internal channels will be bypassed. And going outside is on the rise. It’s been reported that in only seven weeks after the SEC’s program began, there were 334 whistleblower filings. Compliance officer concerns are well founded – that bypassing internal channels will deprive the company of being able to investigate and fix problems before they grow, and company personnel will need to play catch up with investigations in reaction to SEC probes.
We can point to many resolved whistle blowing cases for clear evidence of the potential impact of the SEC’s still relatively new program. One homeowner delinquent on her mortgage ultimately received $18 million for reporting suspected use of fraudulent documents in the bank’s foreclosure process. It’s said that in acting against this homeowner – an attorney and career insurance fraud investigator – the bank “picked the wrong person at the wrong time in the wrong place,“ but the robo-signing and other compliance failures were widespread and surfaced from a number of sources. Nonetheless, this individual was one of six whistleblowers receiving $46.5 million said to be part of the five-bank $25 billion settlement. In an unrelated case, a member of a major bank’s quality control team who reportedly was displeased that the misconduct wasn’t reported to regulators, decided to do so herself – ending up with a settlement of $31 million. And there are many more.
Worth noting is a recent survey that indicates more than one-third of American workers have seen misconduct on the job. While many instances of misconduct have been reported through internal channels, it appears the vast majority have not. Why? The survey shows it’s because of fear of not being able to remain anonymous, and of retaliation. Those two factors, plus the possibility of monetary reward, are reported as key factors in incentivizing internal reporting. And the survey also shows two-thirds of respondents didn’t know about the SEC’s program – at least not yet.
Certainly it’s in a company’s interest to be first to know about alleged misconduct, and compliance officers are working hard to upgrade policies, training, communications, and the internal whistleblower systems, all to encourage internal reporting. Actions to ensure anonymity, with positive responses and nothing close to retaliation, are expected to help. Some companies have begun to pay bounties for valued reports. There are indications that when employees believe their reports will be taken seriously without adverse repercussions, there’s increased likelihood for internal reporting. Law firms and others have provided guidance on which companies are acting. However, it remains to be seen the extent to which the possibility of a huge, life-changing payday by the SEC will be too much to resist. Time will tell.
Richard Steinberg 270004HRBG firstname.lastname@example.org | | Tags:  grc risk_management | 0 Comments | 1,139 Visits
We know that MF Global, the firm run by Jon S. Corzine, recently imploded under the weight of bad bets and huge leverage. Reports say that Corzine, former U.S. Senator, Governor of New Jersey, and co-head of Goldman Sachs, did at MF Global what he did at GS – and that’s take large risks in trading. How, one could ask, could it have turned out so wrong?
Effective risk management processes have at their core identifying, analyzing and managing risks. It will be a while before we know all the details of MF Global’s risk management process, but it appears to have worked reasonably well. Wait, what – is that a misprint? Probably not.
Based on reports, Corzine knew the risks he was taking. Basically, he bet that the European leaders would act in a way to alleviate the sovereign debt crisis. He put over $6 billion of the firm’s money at risk, which with the associated leverage put the firm’s existence at risk. And the firm’s risk officers also knew, and they seemed to have done what they were supposed to – they brought the matter to the board of directors. Reports say a senior risk officer described the situation and the risks to the board, with Corzine present. The risk officer pointed out not only the nature and size of the risks, but also that risks included both potential defaults on the sovereign debt and the bonds losing sufficient value to cause a liquidity crisis at the firm. The directors listened, and decided to approve what Corzine was doing.
Now, we weren’t in the room with the directors, or inside their heads, so we don’t know whether they made a thoughtful and rational business judgment, or whether they rolled over under Corzine’s undue influence. If the latter, then they failed in their job. But if the former, then they determined that they and the firm had a risk appetite large enough to “bet the ranch.”
So, whether this is a failure of risk management will be decided as the investigations continue and more facts emerge. And of course the missing “segregated” client funds is another matter, likely centered on specific internal controls over that money and what control activities might have been overridden by more senior executives. Also at issue is whether regulators did their job effectively. It will be interesting, indeed, to learn more, as no doubt we will as the investigations unfold.