Financial Crime World

Here is the converted article text in Markdown format:

Central Banks: Policy Risks Managed Outside Formal Three Lines of Defense Model

The Solomon Islands Central Bank (CBSI) has been advised by the IMF to strengthen its risk management framework by establishing effective governance structures that facilitate open dialogue and debate on policy options.

Risk Management Outside the Formal Framework

The CBSI was found to be managing risks outside of the formal three lines of defense model, which typically consists of:

  • First-line departments responsible for implementing policies
  • Second-line risk management units that oversee and challenge these activities
  • Third-line internal audit functions that provide independent assurance

Addressing the Gap

To address this gap, the IMF has recommended the following measures:

  • Clearly define risk management roles and responsibilities
    • Assign a member from each department to coordinate the risk management process
    • Ensure each department is discharging its first line of defense responsibilities effectively
  • Adequately resource the second-line risk management function by:
    • Providing training for risk management staff
    • Ensuring they have the capacity to operationalize risk management analysis and reporting

Establishing a Risk Working Group

The IMF has also recommended the establishment of a Risk Working Group (RWG) chaired by the deputy governor. The RWG will be responsible for:

  • Maintaining oversight on the accuracy of risks being identified
  • Aligning on the aggregate risk profile
  • Supporting the Risk Management Unit (RMU) in providing aggregate oversight of material risks to the board

Quarterly Oversight and Reporting

The report stressed the need for structured and quarterly oversight of risk by both the executive and board. To achieve this, the IMF has recommended that:

  • Risk management be included as a recurring item on the executive and board agendas
  • Minutes and action logs from the RWG be provided to both groups for information

Amending Terms of Reference for the Board Audit Committee

The IMF has suggested amending the terms of reference for the Board Audit Committee (BAC) to include risk oversight, enabling the committee to provide effective oversight of risk management and control within the CBSI.

Defining a Risk Appetite Statement

The report highlighted the importance of defining a risk appetite statement, which articulates the tolerance levels that the CBSI is willing to accept in pursuit of its mandate and associated business objectives. The risk appetite statement should be approved by the board and define the approach to managing strategic, financial, and operational risks.

Conclusion

Overall, the IMF’s recommendations aim to strengthen the CBSI’s risk management framework and ensure effective governance structures are in place to manage policy risks outside of the formal three lines of defense model.