0%
 

Course Objectives

After completing this course, you will be able to:

  • Define key concepts in Operational Risk Management, including types of Operational Risk
  • Describe the objectives and governance framework of Operational Risk Management
  • Identify responsibilities across the three lines of defense
  • Describe components of the Operational Risk Management Cycle and supporting tools and processes

Course Navigation Tips

This course is divided into five topics and an end-of-course assessment.

The Home button at the end of each topic takes you to the Home page.

The Menu button provides access to the individual topics.

The Resource button provides a list of useful links.

The Switch Language button lets you switch to a different language.

The Close button ends your training session and closes the course window.

If you are accessing the course from a personal device directly over the Internet (outside of the Citi network), some links may not work if they link to content within Citi’s network. This will not impact your ability to complete the course.

Coming Next

First, what is Operational Risk? Let’s find out.

Operational Risk Management in Everyday Life

All business processes have inherent Operational Risks associated with them. Well-designed and operated controls are required to mitigate these risks to an acceptable level.

In a department store, for example, high-value goods are at risk of theft. To manage this risk, stores must have in place:

  • Preventive controls, to stop the risk from materializing (e.g. locking away high-value items to restrict access)
  • Detective controls, to identify and limit the impact of a risk after it materializes (e.g. a daily inventory check when the store closes for the day)

Such control measures are only effective if they are designed well and implemented as intended. They must be monitored for effectiveness.

Operational Risk Events

An Operational Risk Event is an incident related to Operational Risk. It can have a direct financial impact, either favorable (“Gain”) or unfavorable (“Loss”), on Citi’s profit and loss statement (P&L) (including reserves), or no financial impact.

An Operational Risk Event can take many forms:

Select each item to learn more.

 

Cyber Attack

Hackers infiltrate Citi’s systems and manage to steal client data.

Payment Error

A payment intended for one Citi client is processed to another in error.

Natural Disaster

One of Citi’s offices is damaged by a hurricane.

ORM Core Activities

So how does ORM help Citi manage Operational Risk? ORM’s core activities are aligned to the Risk Management Lifecycle governed by Enterprise Risk Management (ERM): Identify, Measure, Monitor, Control, Report. Some of these core activities will be covered later in this training.

Select each activity to view its purpose.

Risk Taxonomy and Reference Data

Risk Taxonomy and Reference Data

A tiered classification system for the risks associated with Citi’s businesses.

Risk Identification

Risk Identification

Process by which operational risks are identified and assessed for materiality.

Risk & Control Assessment (RCA)

Risk & Control Assessment (RCA)

Process to assess operational risks as well as the controls used to manage them.

Scenario Analysis

Scenario Analysis

Involves constructing hypothetical scenarios or situations that analyze the impact to Citi in the event they would materialize.

ORM Core Activities (Continued)

Select each activity to view its purpose.

Risk Appetite

Risk Appetite

The aggregate level and types of risk Citi is willing to take in order to achieve our strategic objectives and business plan, consistent with applicable capital, liquidity, and other regulatory requirements.

New Activity

New Activity

Framework for assessing whether the risks of a proposed new or modified activity have been identified and sufficiently addressed.

Independent Assurance

Independent Assurance

Governance and principles for ORM’s testing and monitoring of First Line of Defense (1LOD) risk processes, activities, and/or controls.

Control Framework

Control Framework

ORM sets requirements for the design and management of controls and owns the Control Taxonomy.

ORM Core Activities (Continued)

Select each activity to view its purpose.

Issue Management & Lessons Learned

Issue Management & Lessons Learned

Issue Management: The process of identifying and addressing issues, from identification to closure.

Lessons Learned: The process of identifying and reporting root cause and contributing factors of events, to strengthen controls and limit occurrence of similar future events.

Loss Events

Loss Events

Maintaining a centralized repository of operational risk events enables Citi to identify areas of monetary loss, as well as potential control inadequacies.

Management Reporting

Management Reporting

Timely and accurate data helps risk managers make informed decisions.

Capital Measurement

Capital Measurement

Capital measurement (e.g. for Comprehensive Capital Analysis and Review (CCAR)), a critical responsibility for the bank, uses Operational Risk data to help us assess whether we have sufficient capital to withstand a severe economic shock.

Citi’s Risk Taxonomy


Citi’s Group-wide Risk Taxonomy is a classification system for the risks associated with Citi’s businesses. The Risk Taxonomy creates a common risk language that can be used by all Lines of Defense to identify, assess, and monitor risk. It provides the foundation for risk management practices such as Risk Identification and Risk Appetite, both of which we’ll cover in this training.

The hierarchy of the Risk Taxonomy is structured logically, moving from high-level categories to more granular risks (L0 through L4). Level 0s are the primary risk categories, such as Operational Risk. These categories are further defined in the Enterprise Risk Management Framework (ERMF).

A tree with roots formed by the Risk Management Lifecycle: Identify, Measure, Monitor, Control, Report. The tree’s branches are the Level 0 Primary Risk Categories: Market Risk, Strategic Risk, Operational Risk, Credit Risk, Liquidity Risk, Reputation Risk, Compliance Risk.

Operational Risk Level 1 (L1) Categories


We turn our focus now to the L1 Risks, which represent broad risk categories where risk quantity and quality can be assessed using Key Risk Indicators (KRIs), limits, and Internal Audit assessments.

Levels 2 through 4 show more granular risk segments, and you can see these as part of the full risk taxonomy, including descriptions, published on the Operational Risk Management website.

A tree with roots formed by the Risk Management Lifecycle: Identify, Measure, Monitor, Control, Report. The tree’s main branches are the Level 0 Primary Risk Categories: Market Risk, Strategic Risk, Operational Risk, Credit Risk, Liquidity Risk, Reputation Risk, Compliance Risk.

Additional branches represent L1 Risks under Operational Risk: Data Risk, Business Disruption and Safety Risk, Financial Statement Reporting Risk, Regulatory and Management Reporting Risk, Model Risk, Fraud and Theft Risk (excluding Technology), Human Capital Risk, Processing Risk, Third Party Risk, Cyber Risk (including Information Security), Technology Risk.

Think about it…

Think back to an incident that you would recognize as an Operational Risk Event. What led to the incident and what category of Operational Risk was it?

What impact did it have on your daily work, and on the Bank? And what did you learn from the experience?

Coming Next

Next, we’ll find out about the role of the three lines of defense in managing Operational Risk at Citi.

The Three Lines of Defense

At Citi, we are all risk managers. Everyone has a role to play in identifying, measuring, controlling, and monitoring risks to protect our clients and the bank, and that is certainly true for Operational Risk.

To do that, all three lines of defense must work together in a constant feedback loop.

Why? Because we are better when we manage risk together.

Select each line of defense to learn more.

First Line of Defense
Second Line of Defense
Third Line of Defense

First Line of Defense

The first line of defense (1LOD) consists of the businesses and functions responsible for implementing and maintaining effective controls to reduce the Operational Risks they are exposed to.

Second Line of Defense

The second line of defense (2LOD) is responsible for overseeing the risk-taking activities of the first line, and challenging the first line in execution of their risk management responsibilities. The second line consists of Independent Risk Management (IRM) and Independent Compliance Risk Management (ICRM). ORM is part of IRM.

Third Line of Defense

The third line of defense (3LOD), Internal Audit, provides senior management with independent opinions on the effectiveness of the ORM framework as a whole.

Business Risk and Control Committees

A key component of ORM’s governance framework is Business Risk and Control Committees (BRCCs). ORM sets requirements for Group and lower-level BRCCs, so that they can help oversee Operational and Compliance Risks throughout Citi. These committees are managed by the First Line.

The BRCCs provide channels to inform Senior Management about Operational Risk exposures, breaches of Operational Risk appetite, and Operational Risk events, allowing Senior Management to transparently make and document decisions around the mitigation, remediation, or acceptance of Operational Risk exposures.

While promoting a culture of risk awareness and high standards of conduct, the Group BRCC helps ensure that:

  • Risks are adequately identified, monitored, reported, managed, and escalated; and
  • Appropriate action is taken in line with firm-wide strategic objectives and policies, risk appetite thresholds, and regulatory expectations

Coming Next

In the next topic, we’ll learn about the components of the Operational Risk Management Cycle.

Identifying Operational Risk

Risk identification is a crucial initial step in Operational Risk management, particularly for those risks that have the most material impact. Awareness and preparedness are essential elements in risk identification.

Select each button to learn more.

Awareness
Preparedness

Awareness

Risk identification brings awareness of potential risks. By systematically identifying and assessing risks, organizations become more knowledgeable about the threats they face. It helps us understand what could go wrong and how it may impact operations, employees, customers, finances, or our reputation.

Preparedness

Once risks are recognized, we can take appropriate measures to mitigate, avoid, accept, or transfer those risks. Identifying risks allows us to make informed decisions and helps us allocate our resources more wisely.

Measuring Operational Risk

Once risks have been identified, one of the ways we work to measure those risks is through risk appetite. This is the aggregate level and types of risk Citi is willing to take in order to achieve our strategic objectives and business plan, consistent with applicable capital, liquidity, and other regulatory requirements.

Select each item to learn more.

 

Risk Appetite Statements

At Citi, we have a Firm-wide Risk Appetite Statement for Operational Risk.

This Statement is updated annually, in accordance with the Enterprise Risk Management Framework.

Purpose of Statement

The Operational Risk Appetite Statement defines acceptable levels of Operational Risk to ensure:

  • Operational Risk exposures that exceed these levels are escalated to management
  • Actions are taken to bring these exposures back within acceptable levels or formalize a Risk Acceptance

Scenario Analysis

One key part of the risk measurement process is Scenario Analysis, which assesses the likelihood and loss impact of hypothetical Operational Risk events. The hypothetical scenarios are forward-looking, plausible, high-severity, and of low likelihood.

Select each tab to learn more.

Examples
Importance
Outputs

Examples

Some examples of scenarios analyzed include:

  • A rogue trader could impact Citi’s Markets business
  • Citi’s Markets business could suffer significant losses due to a runaway system
  • A cyber incident and data breach could expose Citi’s Cards products to large regulatory fines and settlements

Importance

Citi’s large loss experience is sparse, and Scenario Analysis allow us to investigate what could happen without actually having to experience the loss event.

As an outcome of the program, we can identify unknown risks and exposures, and put plans into place to address these gaps and strengthen controls.

Outputs

There are two key outputs gained from engaging in the Scenario Analysis process:

  • Loss severity is the potential loss amount if the scenario materializes.
  • Management actions (MAs) are actions raised during scenario development that are expected to be beneficial to the management of possible risk concerns and issues.

Monitoring Operational Risk

One key methodology applied to monitor and remediate operational risk issues is through the Issue Management lifecycle.

Select each item to learn more.

 

Operational Risk Issues

An issue occurs when a risk is not mitigated to an acceptable level due to the inadequate design, ineffective execution, or absence of appropriate controls.

Issues can arise from any oversight activities, including assessments, reviews, testing, challenges, monitoring, or business as usual activities from internal parties (Businesses/Functions, Risk, Compliance, Internal Audit) or external parties (such as Regulators or External Auditors).

Issue Management

Issue Management is the process of identifying and addressing issues through the entire Issue Management Lifecycle, from identification to closure.

For more information on Issue Management, review the Global Issue Management Policy.

The stages in the Issue Management Lifecycle: Identification, Evaluation, Remediation/Risk Acceptance, and Closure.

Tracking Issues

Issues are recorded and tracked in the Issue and Corrective Action Plan System (iCAPS).

By effectively managing Issues, Citi can minimize potential damage, protect stakeholders’ interests, and help ensure long-term sustainability of our businesses.

Managing Operational Risk

Businesses and functions must have processes in place that allow them to bring Operational Risk exposures within acceptable levels.

The Operational Risk Management Policy establishes that Operational Risk must be managed at both a granular and an aggregated level. Granular risk exposures (e.g., specific instances of risk) are identified, assessed, monitored, and/or mitigated through Risk and Control Assessments (RCAs).

ORM establishes enterprise-wide minimum requirements for granular RCAs. The objective is to achieve alignment through the use of consistent taxonomies, assessment structure, and methodologies.

Risk and Control Assessments

ORM oversees the Risk and Control Assessment (RCA), which is used to identify and evaluate Operational Risks and gauge the effectiveness of our organization’s controls in managing those risks. ORM establishes the minimum requirements to complete granular RCAs through risk and control identification and assessment, as well as risk management.

Select each tab to learn more.

Inherent Risk Identification and Assessment
Control Identification and Assessment
Residual Risk Management

Inherent Risk Identification and Assessment

All relevant risks that, in the absence of controls, will prevent the business and function from meeting its objectives must be identified and assessed. Such risk is categorized as Inherent Risk.

Inherent Risks must be assessed considering:

  • The likelihood or anticipated frequency of the risk materializing (i.e., “How often could this event occur?”)
  • The significance of impact to the organization should the risk event materialize (i.e., potential financial operational losses, regulatory impact, reputation impact, conduct risk impact and business disruption impact).
Inherent Risk equals Impact multiplied by Likelihood.

Control Identification and Assessment

Once the Inherent Risk is identified and assessed, the key controls mitigating this risk must also be identified and assessed. The controls are evaluated to determine whether they are:

  1. Adequately designed (i.e., in line with the control objective)
  2. Operating in accordance with the stated design

Residual Risk is the amount of risk remaining after the controls have mitigated the risk.

Inherent Risk plus Controls equals Residual Risk.

Residual Risk Management

RCA doesn’t stop at assessing residual risk; the final step is to manage that residual risk so that it is reduced to an acceptable level.

Risk owners must determine the Corrective Action Plans (CAPs) to mitigate individual residual risks that are not in accordance with Citi’s Risk Appetite, or formalize a Risk Acceptance where the residual risk cannot feasibly be reduced any further.

Note: The RCA is an input into the Risk Appetite Assessment Process, but by itself it does not assess if a risk is within or outside of risk appetite – only the Risk Appetite Assessment can determine this.

Reporting Operational Risk

Reporting of Operational Risk incidents is a critical function for our bank. It enables us to identify areas where we might be losing money, as well as potential control inadequacies. In addition, Operational Risk loss data is used toward regulatory requirements and capital calculations.

Reporting Operational Loss – Scenario

Let’s review a situation that can occur with operational risk loss data.

Due to ineffective controls related to trading confirmation, Greg, a trader on the derivates desk, processed an incorrect trade which caused Citi to incur a USD 150,000 loss once corrected. Upon recognizing his error, Greg reported the error to his senior manager, Lee.

Have all necessary actions been taken?

Select the best response and then select Submit.

Loss Capture Reporting

At Citi, all operational risk events that result in an operational loss (or gain) of USD 20,000 or greater must be entered into LCS.

Select each question to learn more.

 

Are there any exceptions?

The one exception is Fraud. All Fraud-related incidents, regardless of value, must be entered into LCS.

What else must be logged in LCS?

In addition to actual loss events realized, LCS also captures the following operational risk events with varying reporting requirements:

  • Near-miss Events
  • Credit Boundary Events
  • Timing Difference Events
  • Regulatory Definition Credit Events

Definitions for each of these event types can be found in the Internal Loss Capture Reporting Central Procedure.

What are the benefits of using LCS?

Having a central repository of Operational Risk events enables us to look for consistent themes and root causes within the event data, which can help limit the occurrence of similar future events.

A review of the lessons learned can often help in strengthening controls, reducing the potential risk of another incident stemming from the same root cause.

Lessons Learned Program

Another key initiative in reporting of risk and strengthening controls is via the Lessons Learned program.

Select each tab to learn more.

Policy
Goals
Roles

Policy

The Lessons Learned Policy establishes the framework and requirements for the timely identification, analysis, reporting and sharing of qualifying events. A qualifying event is an event that exceeds established criteria and thresholds as specified in the Lessons Learned Procedure.

Independent Risk Management and the Business can also identify other meaningful and/or significant events for Lessons Learned treatment that don’t meet minimum thresholds.

Goals

The goals of the program are:

  • To drive lessons from identified events and actions taken to limit occurrence of similar future events
  • To share learnings across other Citi Businesses where similar risk exposure may exist
  • For businesses to leverage the Lessons Learned review to strengthen their process risk controls, reducing future risk stemming from the same root cause

Roles

Within the Lessons Learned process, Businesses must analyze significant internal and external adverse events when there is a reasonable potential for a similar event to (re-)occur in that Business. The Business must document, within a Lessons Learned Report, the analysis of the root cause, contributing and controlling factors, along with remediation plans to reduce the likelihood of a similar event from reoccurring.

Independent Risk Management’s role and responsibility is to:

  • Challenge that Lessons Learned report
  • Ensure its completeness and the robustness of the responses
  • Provide their concurrence as to the root cause and their belief in the effectiveness of the remediation plans

Lastly, Lessons Learned Program Management shares the published Lessons Learned Reports with senior risk managers across the company to expand awareness of the events more broadly, and to have these reports reviewed by a larger audience for consideration of similar possible risk exposure within their respective business units.

Coming Next

In the next topic, you can review what you’ve learned in this course.

Key Takeaways

Select each section to recap what you learned in this course.

 

Understanding Operational Risk

Operational Risk is the risk of loss resulting from inadequate or failed internal processes, people, and systems, or from external events.

Operational Risk Management (ORM) has aligned its core activities to the Risk Management Lifecycle: Identify, Measure, Monitor, Control, Report.

In Citi’s Group-wide Risk Taxonomy, Operational Risk is a Level 0 (L0) risk category that includes a number of L1 risk categories.

Managing Operational Risk

Everyone at Citi has a role to play in identifying, measuring, controlling, and monitoring risks to protect our clients and the bank.

The first line of defense consists of the businesses and functions responsible for implementing and maintaining effective controls. The second line of defense consists of Independent Risk Management (IRM) and Independent Compliance Risk Management (ICRM).

ORM is part of IRM. ORM sets requirements for Business Risk and Control Committees (BRCCs) to help oversee Operational and Compliance Risks throughout Citi.

Operational Risk Management Cycle

Risk identification requires awareness of potential risks and being prepared to take appropriate measures to mitigate, avoid, accept, or transfer those risks.

Risk is measured through risk appetite. The Operational Risk Appetite Statement defines acceptable levels of Operational Risk. Risk measurement also includes Scenario Analysis, which involves constructing hypothetical situations and analyzing their potential impact on Citi.

An issue occurs when a risk is not mitigated to an acceptable level. Monitoring Operational Risk includes recording and tracking issues in the Issue and Corrective Action Plan System (iCAPS).

Businesses and functions must have processes in place to manage Operational Risk by bringing exposures to within acceptable levels. The Risk and Control Assessment (RCA) is used to identify and evaluate Operational Risks and gauge the effectiveness of controls in managing those risks.

Reporting Operational Risk incidents helps us to identify areas where we might be losing money, as well as potential control inadequacies. All operational risk events that result in an operational loss (or gain) of USD 20,000 or greater must be logged in the Loss Capture System.

The Lessons Learned Policy establishes the framework and requirements for the timely identification, analysis, reporting and sharing of qualifying events. The goal of the program includes to drive lessons from identified events, take actions to limit occurrence of similar future events, share learnings across Citi Businesses and leverage lessons learned to strengthen controls.

Coming Next

Now it’s time to check your understanding of the content by completing a short assessment.

Which of the following statements regarding Risk and Control Assessments (RCAs) are TRUE?

Select all that apply and then select Submit.

Which of the following statements are correct regarding the lines of defense?

Select all that apply and then select Submit.

Governance and principles for ORM’s testing and monitoring of the first line of defense (1LOD) processes, activities, and controls are provided through:

Select the best response and then select Submit.

What are the characteristics of hypothetical scenarios generated in the Scenario Analysis process?

Select all that apply and then select Submit.

Which of the following risk types are categorized at Level 0 (L0) in the risk taxonomy?

Select all that apply and then select Submit.

Inherent Risk is typically measured as a function of which two variables?

Select the best response and then select Submit.

Which of the following are types of Operational Risk?

Select all that apply and then select Submit.

Assessment Results

Home
Operational Risk Management Framework – Overview

Welcome
Understanding Operational Risk
Managing Operational Risk
Operational Risk Management Cycle
Conclusion
Assessment