Governance Control Framework Remediation

AUTHOR

Financial Services

 Engagement Summary

In response to the issuance of an MRA from Regulators, a leading global investment bank engaged BIP.Monticello to support the implementation of a new market conduct risk control framework across their global markets and trading business. Specifically, BIP.Monticello was asked to support and implement a new program to improve the overall risk management capabilities and manage market conduct risk.

Case Study Detail

Project Background

Periodically, regulators will examine the trading practices of global investment banks that engage in trading activity for their own and client’s accounts.  As such, many large banks face difficulties in maintaining proper safeguards that prevent the types of trading risks that accompany insufficient trading controls. State and federal regulators identified some shortcomings in detective and preventative controls within our client’s trading operations and directed them to develop internal control and compliance procedures that satisfy regulatory requirements and complies with relevant U.S. laws and regulations governing the firm’s Market activities.

BIP.Monticello played an instrumental role in developing the governance control framework, including design, build, testing, reporting, and stakeholder management.

Engagement Objectives

The Program Management Office (PMO) consisted of several workstreams to design, build, and test the control framework and to remediate the deficiencies. This enabled the team to utilize a mixed approach of implementing new control frameworks while bolstering and enhancing existing policies.


To coordinate the execution and interactions among the workstreams, a governance forum was created. This cross-functional working group convened weekly to review program progress and changes, discuss challenges and solutions, and resolve issues as they arose. Additionally, a bi-weekly program steering committee provided a governance forum and an escalation path to the bank’s senior leadership to ensure that changes in the program’s resources, budget, and scope as well as their impacts were discussed. Overall, BIP. Monticello was responsible for supporting program governance, change management and reporting.

Business Value

BIP.Monticello partnered with the client’s Business, Compliance, and Technology teams to implement the required enhancements to our client’s governance and control framework. By leveraging our expertise in data analytics, trading operations, and program management, BIP.Monticello played a critical role in helping our client to meet its regulatory commitments for mitigating market conduct risk and implementing robust controls in its currency trading business.

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