RISK MANAGEMENT SUPPORT OF A UK SUBSIDIARY, EU BANK

SUMMARY

The client was an EU bank that had established a UK subsidiary to continue the activities of their currently passported branch after Brexit. The goal of the project was to assist the client with developing documentation that aligned with internal expectations and regulatory requirements in the UK.

Avantage Reply reviewed the risk management framework documentation for the subsidiary and four key documents for the subsidiary in the UK based on FCA regulation.

CUSTOMER GOALS

The principal objective of the client was to draft documents and agree with relevant stakeholders to ensure the documents are compliant with FCA requirements and based upon the existing the Group Risk Management Framework:

• Risk Appetite Statement
• Risk Policy (and procedures);
• Risk Register; and
• Risk report templates for the CEO, key management forums, and Board.

CHALLENGES

The client was in the process of transitioning its UK branch into a subsidiary, driven by Brexit. The principal challenges arose from:

1. Tight deadlines given rapidly approaching end of transition period;
2. Internationally spread Group operations and ensuring the documents were developed through robust governance processes;
3. Ensuring that the local regulatory submissions and internal documents aligned to both the Global standards and UK FCA requirements
4. Ensuring that the documents were produced in an accelerated, appropriate and proportionate manner.

APPROACH AND SOLUTION

An initial working session was used to identify the areas of focus in risk management framework for the client as well as to gather previous documentation.

Key stakeholders were confirmed, and careful analysis and review were undertaken of the documentation from the Group. Subsequently, four FCA-aligned artefacts were drafted, with continuous review from the client.

Weekly management reviews and C-Suite involvement were ensured (from Group and local perspective) to enable robust review and challenge.