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How to Manage and Prevent EUC Risks

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Citi’s Enterprise Risk Management Training Program

Enterprise Risk Management Training Program Risk And Controls Policy Knowledge Common Risk and Controls Skills Specialized Risk and Control Skills

Why This?

This course is part of Citi's Enterprise Risk Management Training Program (ERMTP), a series of courses which will build your understanding of your risk and control responsibilities.

Why Now?

The Enterprise Risk Management Framework (ERMF) is Citi’s standard for managing risk. As part of Citi’s Enterprise Risk Management Framework (ERMF) supporting capabilities, we are committed to equipping all Citi staff with knowledge and training to carry out day-to-day risk and control responsibilities.

Why Us?

Managing risk is everyone’s job at Citi. We are all risk managers. Risk is inherent to Citi’s business and cannot be avoided. Everyone must be vigilant and manage risk with consistency and accountability, including compliance with applicable laws and regulations.

What’s the Win?

Awareness and consistent understanding of risk and controls policy knowledge, roles and responsibilities across all lines of defense.

Introduction to the ERMF


The ERMF establishes an overarching, integrated, and consistent approach to risk management firm wide.

The ERMF has four pillars, as outlined in the following diagram.

Please note: To better understand how Citi manages certain risks, this training will specifically focus on Control within Pillar 3 (Risk Management) of the ERMF. The remaining pillars are addressed in other ERMTP training programs.

The four pillars of Citi’s ERM Framework.
Pillar 1: Culture includes Values, Behaviors and Leadership Principles, and Performance Management
Pillar 2: Governance includes Board and Management, Board Oversight, Delegation, Executive Management, Committees and Escalation, Lines of Defense, and Policies, Standards and Procedures.
Pillar 3: Risk Management covers the Risk Management Lifecycle (Identify, Measure, Monitor, Control, Report), Financial Risks (Credit, Market (Trading), Market (Non-Trading), Liquidity), and Non-Financial Risks (Operational, Compliance, Strategic, Reputation).
Pillar 4: Enterprise Programs covers Enterprise Risk Identification, Risk Appetite and Limits, Stress Testing, Strategic Planning, and New Activities Approval.
Supporting Capabilities are: Talent, Performance Management and Compensation; Communication and Training; Technology and Data; and Models and Analytics.

Course Learning Objectives

Upon completion of this course, you will be able to:

  • Identify End User Computing (EUC) developed tools in your daily activities
  • Recall the risks associated with using EUCs
  • Explain your responsibilities with identifying EUC risk
  • Describe your responsibilities with preventing EUC risk
  • Identify solutions to reduce the risk associated with EUCs

Completion Criteria

This course contains a final assessment. You must score 80% or higher on the assessment to receive credit for this training.

This course also includes an optional test-out. If you pass, you can bypass the course content and final assessment and receive credit for completion.

If you prefer you can skip the test-out and go straight to the content.

What is End User Computing (EUC)?

Jared’s Innovative Idea

Let’s consider a scenario where our daily activities could introduce or contribute towards End User Computing (EUC) risk.

Jared, a senior analyst in the Services business, needs to compile a monthly financial report for his manager.

Existing systems don't offer a streamlined way to gather and analyze data from various sources.

To simplify his workflow, Jared creates a customized Excel spreadsheet with formulas, functions, and other Logic to automate data organization, calculations, and report generation.

Did Jared’s Innovative Idea Introduce an EUC Risk?

The results of the spreadsheet could then be manually uploaded into a Citi system and reported out in the Services monthly financial report.

Did Jared introduce an EUC risk?

Select the best response from the three options and then select Submit.

Please use the Space key only when selecting a radio option with the keyboard. The Enter key is not fully supported. If the Enter key has been used to select a radio option, please use the Escape key. Then you will be able to use the Space key again to select a radio option.

Overview of End User Computing

An EUC refers to tools that meet all the following criteria:

  • Is developed or managed by an End User (any Staff); AND
  • Is NOT controlled by an Information Technology approved process (e.g., Citi Solution Delivery Life Cycle Standard (CSDLC)); AND
  • Contains any Logic; AND
  • Is in regular and repeated use as part of a Business Process; AND
  • Is used for regulatory, management, and governance committee reporting, uploaded to Authorized Data (System of Record (SoR) or Authorized Redistributor (AR)), or supports a business process in their Manager’s Control Assessment (MCA).

Why are EUC Tools Created?

EUC tools are created when approved IT solutions (e.g., Core IT Systems) cannot be enhanced in the time required or alternative technology solutions are unavailable.

Examples of EUC tools include use of programming or scripting languages in:

  • Spreadsheets (e.g., MS Excel)
  • Databases (e.g., MS Access)
  • Business intelligence tools

What is Not EUC?

It is important to distinguish EUCs from tools managed by Information Technology (IT).

Tools developed by IT and centrally managed and controlled such as Workday or Citi Travel & Expense are NOT EUCs.

Similarly, tools used to fulfil a one-time task or have no Logic to automate an activity are also NOT considered EUCs.

Additional examples of tools that do not meet the criteria of EUCs include:

  • A template downloaded from Citi Market Place for bulk upload request
  • MS Excel file used to hold reference data as input to a report with no data manipulation or calculation made to the file
  • MS PowerPoint or Excel spreadsheet used to consolidate data depicting results to prepare a narrative without computations, or pivots of the data

Now that we have differentiated between EUCs and non-EUCs, let’s explore how their use can introduce risk to Citi.

How do EUCs Introduce Risk?

EUC tools introduce risks to the organization.

Although EUCs can enhance efficiency, they may also pose risks if not properly managed. In cases like Jared’s, Citi employees may create EUCs when approved Citi technology solutions are not available.

Without appropriate controls, EUCs can put Citi at risk of data breaches and loss or corruption that could cause harm to our firm or our clients.

To proceed, select each button to reveal the impacts of these risks.

Data Integrity

Data Integrity

EUCs may contain inaccurate or outdated data, impacting financial and regulatory reporting or critical Citi Applications.

Business Processes Disruptions

Business Processes Disruptions

An error in EUC could disrupt the approval of a transaction or a key operational process.

Compliance Issues

Compliance Issues

EUCs may not fully adhere to Citi's IT Security Standards including critical policies such as but not limited to Technology, Cyber Security, Data Privacy, and Cross Border, thereby increasing the potential risk of data breaches.

Coming Next

Next, you’ll discover what you should do if you encounter an EUC.

How to Reduce EUC Risk

Reduce Reliance on EUCs

As risk managers, Citi staff are responsible for reducing reliance on EUCs in Citi’s business processes. Before creating a new EUC or continuing to use an existing one, consider restructuring the process or consider IT-approved alternatives to eliminate or reduce risk.

Examples of IT-approved alternative solutions are IT-enabled Smart Solution (ITeSS) or a Citi Core IT system technology.

To proceed, select each possible alternative to learn more.

Business re-structuring/
Process Engineering
Core IT Systems
IT-enabled Smart
Solutions (ITeSS)

Business re-structuring/ Process Engineering

Change or modification of the business processes resulting in elimination of the EUC.

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Core IT Systems

Check if existing Citi systems might already offer the functionality you need or if a system can be enhanced.

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IT-enabled Smart Solutions (ITeSS)

An ITeSS is created by an end-user in collaboration with Business and Function IT using approved ITeSS software on a Citigroup Systems Inventory (CSI) registered platform compliant with the ITeSS Standard.

ITeSS have higher levels of controls and oversight from IT, making them a safer alternative to EUCs.

The EUC Lifecycle

If you encounter an EUC, or are considering creating one, you should follow the EUC lifecycle. Seek guidance from your:

  • Manager;
  • Business/Function EUC Champion; and/or
  • Information Technology partner.

Access the EUC Champion list here.

To proceed, select each step to learn more about the EUC lifecycle.

 

Identification and Pre-Creation

Identification

Use the EUC and ITeSS Decision Tree to identify if a tool is an EUC.

This tool guides you through a series of questions to classify the tool accurately.

Note: The Decision Tree can also identify whether a tool is an ITeSS.

For this training, we are using the EUC and ITeSS Decision Tree for identifying EUCs. You can access the tree on the EUC & ITeSS Decision Tree and Quick Reference Guide.

Pre-Creation

Perform sufficient pre-creation due diligence prior to creating new EUCs.

Registration

If the tool is identified as an EUC, register it in the EUC Inventory Tool.

This helps Citi track and manage potential risks associated with EUCs across the organization.

Risk Assessment

Assess the risks associated with the EUC. Risk Assessment classifications are Critical, High, Medium and Low Risk EUC.

Control Implementation

Ensure the EUC has appropriate controls to mitigate potential negative impacts on data, processes, and compliance (e.g., access and entitlement control, data integrity, and version controls.)

Risk Reduction

Consider IT-approved alternatives to EUCs that help eliminate or reduce risk as covered in the Reduce Reliance on EUCs section.

How Can Jared Use the Decision Tree to Reduce EUC Risk?

Jared reached out to Priya, the EUC Champion for the Services business, for assistance with his new spreadsheet.

Priya recommended that Jared use the EUC and ITeSS Decision Tree to determine if the new spreadsheet he created meets the criteria of an EUC.

View Jared’s responses to the decision tree questions.

Conduct Risk Assessment

The results of Jared’s EUC & ITeSS Decision Tree criteria indicate the spreadsheet is an EUC.

As an EUC, the spreadsheet does not comply with the EUC Policy & Standard and therefore could be a potential risk exposure to the firm if Jared continues to use the spreadsheet.

Now that Jared has identified that he’s using an EUC, he proceeds to register the EUC in the EUC Inventory Tool, conducts a risk assessment, and implement appropriate controls.

As a next step, Jared decided to work with Priya to explore replacing the spreadsheet with an IT-approved alternative solution.

This helps reduce the reliance on the End User Computing (EUC) tool and mitigates EUC risks with higher levels of controls, which supports the safety and soundness of the firm.

Coming Next

Up next, there’s a summary of key takeaways from this training.

Key Takeaways

Recap of What You Learned

  • An End User Computing (EUC) tool is a solution Citi staff create to automate a regular and repeated process not controlled by Citi-approved Information Technology.
  • Citi staff should be aware of the risks associated with EUCs.
  • The EUC and ITeSS Decision Tree should be used to identify if a tool is an EUC or ITeSS.
  • Remember, it’s your responsibility to identify existing EUCs and/or consider IT-approved alternatives to prevent the use of EUCs.

For further guidance, reach out to your EUC Champion in your Business/Function for assistance with the EUC and ITeSS Decision Tree and/or to explore ITeSS and other solutions as an alternative to EUCs.

Coming Next

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

Jared developed a spreadsheet that contained Logic (not controlled by an Information Technology approved process) for the month-end report, which then was uploaded to a Citi system.

What tool would this be considered?

Select the best response from the four options and then select Submit.

Please use the Space key only when selecting a radio option with the keyboard. The Enter key is not fully supported. If the Enter key has been used to select a radio option, please use the Escape key. Then you will be able to use the Space key again to select a radio option.

Which of the following are solutions to reduce the risk associated with EUCs?

Select the best response from the four options and then select Submit.

Please use the Space key only when selecting a radio option with the keyboard. The Enter key is not fully supported. If the Enter key has been used to select a radio option, please use the Escape key. Then you will be able to use the Space key again to select a radio option.

Which of the following is NOT a risk associated with End User Computing (EUC) tools?

Select the best response from the four options and then select Submit.

Please use the Space key only when selecting a radio option with the keyboard. The Enter key is not fully supported. If the Enter key has been used to select a radio option, please use the Escape key. Then you will be able to use the Space key again to select a radio option.

What resource can assist you to identify if you have an EUC?

Select the best response from the four options and then select Submit.

Please use the Space key only when selecting a radio option with the keyboard. The Enter key is not fully supported. If the Enter key has been used to select a radio option, please use the Escape key. Then you will be able to use the Space key again to select a radio option.

Identify, Register and Risk Assess are the first 3 responsibilities performed when an EUC is discovered. What are the next responsibilities?

Select the best response from the four options and then select Submit.

Please use the Space key only when selecting a radio option with the keyboard. The Enter key is not fully supported. If the Enter key has been used to select a radio option, please use the Escape key. Then you will be able to use the Space key again to select a radio option.

Home

How to Manage and Prevent EUC Risks
What is End User Computing (EUC)?
How to Reduce EUC Risk
Key Takeaways
Assessment

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