Збірник наукових праць. 2014.

Випуск 38

УДК 336.71
O. B. Afanasyeva, Ph. D. in Economics,
D. O. Riabichenko, Ph. D. student,
Ukrainian Academy of Banking of the National Bank of Ukraine

OPERATIONAL RISK GOVERNANCE:

THE BASEL APPROACH 1

This paper analyses key documents of Basel Committee which concern operational risk
governance and identifies the interconnectedness between risk source, type of the event leading
to losses, loss type and its distribution by business lines. The comparative characteristic of the
main operational risk governance stages is provided and the relationships between governance
bodies are overviewed.
Keywords: operational risk, corporate governance, Basel Committee on Banking
Supervision, board of directors.
Problem statement. Due to financial crisis events in recent years the
successful operation of financial institutions in rapidly changeable circumstances
depends on the ability to appreciate correctly and assume risks. Risk governance
that has always been pressing became so called “problem of today”. In this light
the Board of Directors and bank’s management take the responsibility for active
promotion of changes in the corporate culture that helps to consider decision
concerning risk-taking and risk appetite measuring.
The other important issue applies to organization of risk governance in the
bank in the most effective way. In accordance with Basel Committee Principles for
Enhancing Corporate Governance (dated 2010) this function is recommended to be
referred to Chief Risk Officer (CRO). This executive is supposed to be
independent and have interaction with other chief executives, including
communication with the Board of Directors. So, it explains the necessity of
definition of effective organizational system of CRO subordination to the CEO and
Board, and also link startup between corporate governance and risk governance
inside the bank.
Not in question the fact that operational risk factors have rising influence on
banking performance. Thus, frauds, human errors, omissions or sabotages can
seriously lessen bank profits and blacken image. Corporate governance of the
bank should be focused on identification, warning and non-admission of reaching
destructive level operational risk by means of having an influence upon
processes, technologies and people. These are the main sources of considered bank
risk.
Operational risk has emerged as top priority for financial institutions in recent
years. This is partly due to an increasing emphasis by supervisory authorities who
are pressing for increasingly stringent regulations and more punitive measures for
non-compliance. It is also due to the clear evidence of the harm that non-
compliance can do to a company’s reputation.

© O. B. Afanasyeva, D. O. Riabichenko, 2014

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As known “operational risk is as old as the banking industry itself”, that’s

why we should answer the question “Why is it paid more attention to this risk
recently?” First of all, this is due to qualitative changes in the banking sector: the
development of a large number of banking products, the complexity of
technological processes and introduction of sophisticated modern technical
equipment. Moreover, the impact of globalization leads to increasing in the
intensity of consolidation processes in banks, increasing of their activity, thus,
operational risk increases disproportionately to rising of banks’ active operations.
Basel II has raised discipline of managing the operational risk in banks.
The new economic and financial conditions (including post-crisis rehabilitation)
brought to revision of the existing regulatory standard. Its reflection, notably
Basel III, proposes slightly other modified operation risk management. As the
Basel recommendations are not obligatory, but advisable, bank may also
implement its own model of conducting this type of risk as an integral part of
effective corporate governance. The absence of unified approach to realization
of operational risk management raises an important task to work it out according
to principles of effective corporate governance and with a glance of Basel
recommendations.
Analysis of the latest publications. Academics such as Julia Allen, Jim
Cebula [1], Dennis I. Dickstein, Robert H. Flast [2], Claus Huber, Daniel Imfeld
[4], James L. Jones [6], Stuart Robinson, John Rowland [15], David Tattam [17],
Günther Thonabauer, Barbara Nösslinger [18], Benedikt Wahler [19] paid much
attention to operational risk governance, but the issue of the interconnectedness
between corporate governance and operational risk governance in context of Basel
recommendations is out of focus in their researches.
The main aim of the article is to overview Basel documents which touch
upon operational risk governance and identify the main steps of governance
process in accordance with appropriate governance levels.
Main results of the study. Traditionally, risks-managers considered
operational risk as a direction of secondary effort. It is connected with extensive
character of a problem, subjectivity which, as a rule, is inherent in ways of
management of operational risk and ways of its control, difficulties in
search/consolidation of the data and qualitative character of decisions.
At the same time it is necessary to notice that operational risk value has
considerably increased lately under the influence of financial markets
globalization, development of IT in banks (enhancement of electronic
calculations systems, remote customer service and interbank information
communications).
Operational risk losses are unpredictable most of the time. Unfortunately, it
happens too often that organizations are affected by substantial losses due to
events they fail to foresee. These disastrous financial effects are usually caused by
the lack of an effective management of operational risk within the corporation.

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The January 2012 issue of the Operational Risk & Regulation magazine
mentions a list of the top ten loss events for financial services companies in 2011,
based on information from SAS OpRisk Global Data (Table 1).

Table 1 – The biggest operational risk losses for financial institutions in

2011
Position Name of the financial Losses,
Country Cause
in ranking institution million USD
1 Busan Savings Bank South Korea 4 290 Internal fraud
2 UBS Switzerland 2 300 Unauthorized activity
3 Ally Financial USA 787 Improper business practices
4 Bank of America USA 410 Own overdraft fee rules
5 77 Bank Japan 378 Tsunami
6 Axa Rosenberg Group USA 242 Computer coding error
7 JP Morgan Securities USA 228 Improper business practices
8 Morgan Keegan USA 201 Misleading investors
9 Securities America USA 180 Advisory activities
10 China Construction Bank China 174 External fraud

Operational risk value has considerably increased lately under the influence
of financial markets globalization, development of IT in banks – enhancement of
electronic calculations systems, remote customer service and interbank
information communications. Operational risks became the reason of the loudest
scandals in the financial world. Systematizing of such categories as a risk source,
type of the event leading to losses, and loss type is presented in Figure 1.

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External events Corporate Finance

Trading & Sales

Internal sources

Losses by Business Lines

Retail Banking
People
Commercial Banking

Payment and Settlement

Systems Processes
Agency Services

Asset Management

Sources of risk Retail Brokerage

Loss Event Types Types of Losses

Internal fraud Write-Down

Loss of Recourse
External fraud
Restitution
Explicit

Legal Liability
Employment Practices and Workplace Safety
Loss of Damage to Assets

Clients, Products & Business Practices Regulatory & Compliance

Service Levels
Damage to Physical Assets
Foregone Income
Implicit

Business disruption and system failures Quality

Execution, Delivery Reputation

& Process Management Business Interruption

Figure 1 – Connection between sources of risk,

types of events that leads to losses and types of losses

According to Basel committee approach there are four major sources of risk:
people, systems, processes and external factors. In case of “white stains” in
operational risk management, interaction of this sources leads to generation of
events which may cause increase of losses in case of their realization. Types of
losses can be divided into measurable and non-measurable and should be
reallocated to corresponding business lines.
The operational risk is closely connected with other risks; particularly it is
capable to lead to large direct and indirect losses of bank with influence of market
risk and credit risk (Table 2).
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Table 2 – Market, credit and operational risks connection [20]

Operational risk Market risk Credit risk
Incorrect data input Loss trade position Wrong credit value
Incorrect market information Incorrect current cost evaluation Wrong reserve value, incorrect
evaluation of credit portfolio
Absence of limit control Exceed of limits Exceed of limits
Incorrect confirmations Wrong hedging Wrong credit or reserves values
Absence of event control Missed event dates Missed payments
Report delay “Blind” trade Unauthorized credit issue

So, the operating risk management problem is more actual first of all because
of existence of close connection between all of banks’ risks. When constructing the
organizational and functional structure it is necessary to consider integrated
approach of risk-management system in bank.
Basel committee recommendations are a directing vector for financial
institutions of the majority countries. As a result of the analysis, the basic
supervisor documents concerning management of operational risk have been
divided into 4 groups:
 corporate governance issues;
 general aspects and Basel I, II, III;
 regulation of the AMA;
 influence on the other aspects of banking activity.
Basel Committee on Banking Supervision throughout long time works over
development of appropriate methods of corporate governance in banking sector.
The first document has been published in 1999, and in 2006 it has been reviewed
and republished in the form of Principles [3] which, in turn, are formulated on a
basis and in development of the document of Organization for Economic Cooperation
and Development in edition of 2004 [11].
In the Basel committee document (2006) key aspects of corporate
governance had been formulated:
 the board of directors should actively participate in the statement of
strategy of the credit organization;
 authority division must be set up and maintained clearly;
 policies of remuneration payment should correspond to long-term
objectives of credit organization;
 adequate risk management in case of insufficient transparency of credit
operations must be provided.
Since publication of these recommendations a number of cases of deviation
from Principles of effective corporate governance had been revealed. Many of
these cases were visually shown during financial crisis which has begun in 2007.
It is necessary to admit inappropriate control on activities of executives from
board of directors, inappropriate risk management, deliberate complication or
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hiding organizational structures of credit organizations and types of their

activities. Taking this into account Basel committee took decision to publish new
edition of Principles [9].
In the Basel I accord under the capital, published in July, 1988, the
operational risk was not considered as one of major, and it was not used in capital
sufficiency calculation. In July, 1989 the Basel committee issued the publication
“Risks in computer and telecommunication systems” [14], admitting growth of
banks risks in connection with rapid growth of their activities automation.
“Operational risk” term has not been entered yet, but Basel allocates separate
group of risks, such as: insufficient management of the information confidentiality;
computer programs errors and data input errors; fraudulent actions with use of
information systems of bank; failures of programs and the equipment and a
business stop; inefficient development of the IT Infrastructure; risks of the data
loss. The document published in 1998 “Risk Management for Electronic Banking
and Electronic Money Activities” [13] has specified “the risks arising in
connection with considerable lacks (defects) of reliability and integrity of
information systems” and approaches to their management.
In September 1998 the Basel committee had been issued the special
document “Operational Risk Management” [7], setting management principles by
the operational risks determined “by contradiction” as risks, not being credit and
market. The major document of operational risks management methodology was
“Sound Practices for Management and Supervision of Operational Risk” [16]
issued by Basel committee in February, 2003. Determination of operational risk
has not been given yet, however, in the document it is accurately registered what
sort of risks should be understood as operational – the examples of operational risk
grouped in seven categories. Besides, ten recommended principles of reasonable
management of operational risks of bank are reflected in the document.
Lately banks and supervisors have obtained additional knowledge and
experience in operational risk control systems application. Besides, expansion of
banks and supervisors experience of an appropriate business practice
establishment were promoted by suffered losses data gathering, by studying of
quantitative consequences, and also a number of the analyst researches devoted to
problems of management, data gathering and modeling of operational risk
measurement methods.
Considering these changes, the Committee has made the decision on
necessity of the document of 2003 adjustment taking into account enhancement
of appropriate operational risk management practice applied now in banks. The
current version entitled “Principles for the Sound Management of Operational
Risk” [10] contains an appraisal of appropriate practice and the detailed
description of eleven principles of operational risk appropriate management
which are divided into groups: Fundamental principles of operational risk
management (2), Governance (The Board of Directors (2), Senior Management
(1)), Risk Management Environment (Identification and Assessment (2),

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Monitoring and Reporting (1), Control and Mitigation (1), Business Resiliency
and Continuity (1)), Role of Disclosure (1).
The document “Operational risk transfer across financial sectors” [8] issued
in August 2003 puts on practical aspects of management and includes such basic
elements as definition of the term, events that lead to losses (Internal fraud,
External fraud, Employment practices and workplace safety, Clients, products and
business practices, Damage to physical assets, Business disruption and system
failures, Execution, delivery and process management). It can be stated that
recommendations from this document have been included to Basel II soon. The
Accord defines operational risk as “the risk of loss resulting from inadequate or
failed internal processes, people and systems or from external events” [5]. Basel II
gives special place to operational risks because they position the 2nd place by the
amount of losses in the activity of European banks between credit (1 st place) and
market (3rd place) risks. Considering this, the document reasonably recommends to
deal operational risk as an individual risk category that should be maintained by the
definite amount of bank equity capital called “economic capital for operational risk”.
The document includes recommendations concerning methods of capital assessment
for operational risk (BIA, TSA (ASA), AMA) and appropriate criteria for these
methods.
One must admit that Basel III (December 2010) did not introduce innovations
into operational risk management: banks are still recommended to be guided by
prior approach.
The most absolute method in this context is AMA. Its application gives to
banks definite level of latitude and flexibility, but at the time with the aim of
trespasses or abuses non-admission Basel Committee has issued a number of
significant papers regulating the AMA implementation.
The last group of Basel Committee documents in the area of operational
risk is related to its impact on the other spheres of banking activity: FX
transactions (“Supervisory Guidance for Managing Settlement Risk in Foreign
Exchange Transactions” (September 2000), updated consultative version was
published in August 2012 – “Supervisory guidance for managing risks associated
with the settlement of foreign exchange transactions”), outsourcing (“Outsourcing
in Financial Services” (February 2005)), business continuity (“High-level
principles for business continuity” (August 2006)).
This group of documents is not aimed at direct control of operational risk, but
contains implicit recommendations to its governance. The fact of existence of this
type of papers confirms the hypothesis that bank risks don’t appear singly and
are inseparably linked both between each other, and with other aspects of
banking activity. That is why, the complex approach to bank risks governance is
the only effective way out.
Mechanism of operational risk governance is a set of stages and procedures
implemented sequentially to reach defined aims. Although the list of stages differ
among different approaches (Table 3), it must be admitted that differences are
evoked by tasks of scientific investigation, but the essence is common.

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Table 3 – Comparison of approaches to the basic steps of the

operational risk governance mechanism
Author Main steps
Benedikt Wahler Identification; Assessment; Risk control measures selection;
Risk control measures implementation; Monitoring and reviewing
Stuart Robinson, Risk identification; Self-assessment by operational management;
John Rowland Scenario development; Senior management review; workshop; Board review
Günther Thonabauer, Identification; Assessment; Treatment; Monitoring
Barbara Nösslinger
Claus Huber, Risk inventory; Reassessment measurement; Update of Control Inventory;
Daniel Imfeld Risk Mitigation; Controlling; Reporting
Julia Allen, Risk Planning; Risk Identification; Risk Analysis; Risk Response;
Jim Cebula Risk Monitoring and Control
Dennis I. Dickstein, Determine potential risk; Monitor risk; Manage risk; Set and update
Robert H. Flast the risk environment
David Tattam Establish the context; Identify risks; Analyse risks; Evaluate risks;
Monitor and review; Record the risk management process
James L. Jones Identify hazards; Assess hazards to determine risk; Develop controls
and make risk decisions; Implement controls; Supervise and evaluate
This research is based on Basel Committee approach that is represented
mainly in Principles for the Sound Management of Operational Risk (2011). The
main stages of operational risk governance according to this paper are
identification, assessment, monitoring, and control/mitigation.
Comprehensive risk governance system helps shareholders to be aware of
the situation in the bank and to trust the Board. Let’s have a survey on the main risk
governing bodies and their duties that differ across banks, but may have similar
structure (Figure 2).

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Bodies

Risk Committee Board of Directors Audit Committee

of defence
First line
CEO CRO
Governance

Second line Operational Risk Committee

of defence
Credit Risk Committee

Market Risk Committee

Other Risk Committee

Responsible executives of the relevant business directions

Management
(e.g., operational risk officers)

Figure 2 – Governance bodies’ subordination

Risk governance system is aimed to ensure proper management of operational

risk together with flexibility and steadiness on its every level.
At the first line of defence the highest body is Board of Directors that
provides risk oversight, adopts bank risk management strategy, defines the
acceptable (secure) risk level, risk appetite by assessing the bank’s risk and risk-
bearing capacity and assesses risk management efficiency. This is the primary
level of risk governance in banking organization.
Board of Directors approves internal statutes that regulate basic principles of risk
governance, in particular operational risk; provides organizational structure
implementation that fits the main principles of operational risk governance;
controls the completeness and periodicity of internal control of operational risk
managing of individual departments and the whole bank; controls the
completeness and periodicity of reports concerning operational risk estimation;
assesses the effectiveness of operational risk governance.
Board of Directors establishes the committees that are responsible for definite
missions. According to Basel recommendations in context of risk governance the
important task is to provide operation of Risk Management Committee which is
formed by Board members. Researches of leading banks held in 35 largest
organizations [12] evidence that in half of respondent banks there is an overall
Risk Committee. The others have Risk Committee for specific risk only (34 %) or
have just Audit Committee (16 %). Committee dedicated to risk governance at the
Board level empowers to cover the whole image to the Board which, in turn,
contributes to reducing decision-making time.
The other point about Risk Committee is independency of its members.
Directors’ independency implies meeting requirements of New York Stock

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Exchange Listed Company Manual or other applicable law and includes absence
of management or financial responsibility, absence of any privileges concerning
deposit, loan, investment or other activity within the bank or its subsidiaries.
Risk Committee is responsible for reviewing bank risk governance strategies
and procedures, and providing suggestions to the Board of Directors; reviewing the
bank’s major operational risk activities; monitoring the implementation of the
bank’s risk governance strategies and procedures; regularly assessing the duty
performance of risk management and internal control by the senior management
and departments of the bank, including regularly hearing their reports and
requesting improvements; monitoring compliance with operational risk-related
regulatory requirements.
In a number of financial institutes in a structure of Board of Directors there is
Audit Committee responsible also for risk oversight. It substitutes Risk Committee
in governance of financial risks, so the point is that it is also important for
providing effectiveness of banking activity to account and supervise all types of
risks, but not only financial. That explains the actuality of Risk Committees in
the Board.
Chief Risk Officer (CRO) stands for senior executive with the primary
responsibility – risk governance and elaboration of risk management strategy. CRO
regularly presents the report to the Board of Directors that sums up the problems
and perspectives concerning risk dealing. CRO carries out operational risk oversight
activities (which cooperate closely with other risks supervision) to maintain a
strict risk control and to help ensure that risk capital is enforced wisely.
The analysis of the main trends of improving CRO activity especially after
global financial crisis allows us to define the following requirements for
enhancement of risk framework within banking institutions:
1. Reporting of the CRO to CEO and directly to the Board. Figure 3 presents
the most common ways of CRO subordination. According to
investigations banks perform significantly better in the financial crisis.

I. CRO → CEO About 49 % of executives primarily responsible for risk

II. CRO → CFO About 28–30 % of executives primarily responsible for risk

III. CRO → BoD Tendency to growing role of this type of reporting

Figure 3 – Models of CRO subordination amongst largest banks [12]

2. The fulfillment of previous issue enables the access of the CRO to the Board
of Directors. This factor promotes decision-making process, shortens time
for important tasks implementation in crisis periods.
3. CRO should have specific set of skills that includes sufficient experience and
qualifications, banking market and product knowledge, mastery of risk

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disciplines, broad financial expertise, and also personal professional

qualities: strategic thinking, credibility, eye for details, etc.
To summarize the collaboration of CRO and Board of Directors (BoD) in
context of risk governance one must admit that the task of CRO is to implement
risk management program, and BoD oversees the effectiveness of this procedure.
The second line of defense assumes implementation of committees for
managing the specific type of risk. It is reasonable to establish Operational Risk
Committee, Credit Risk Committee, Market Risk Committee, etc. They report to
CRO on regular basis that enables him to make decision, to get an overall image and
to inform the Board concerning significant changes in risk governance framework.
It is important especially in context of operational risks, because they often may
not be connected to market changes and induced by defects or technological
failures, so time becomes critical factor. The lower level could be represented by
Operational risk officers or equivalent.
Conclusions. Fundamentally, the global crisis was a failure of risk
management, or rather a failure to apply risk management at all levels, to
understand properly the risks being run and to have a risk governance process in
place in which risk management was key and was an accepted challenge to
executives’ decisions. And as so much of risk management is about instilling proper
risk behaviors and disciplines, risk management failure, the fundamental cause
of the crisis, is mainly about people risk, which lies at the heart of operational
risk.
Because operational risk management is evolving and the business
environment is constantly changing, management should ensure that the
policies, processes and systems remain sufficiently robust. Improvements in
operational risk management depend on the degree to which operational risk
managers’ concerns are considered and on the willingness of senior management
to act promptly and appropriately on their warnings.
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Отримано 30.08.2013
Анотація
У статті проведено аналіз основних документів Базельського комітету,
що стосуються управління операційним ризиком, та визначено взаємозв’язок
між джерелами ризику, типами подій, що призводять до втрат, і розподілом
цих втрат за бізнес-напрямками. Наведено порівняльну характеристику етапів
управління операційним ризиком та охарактеризовано взаємозв’язки між
суб’єктами управління.

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