Ongoing Risk Management

Monitoring and Testing

To ensure that risk is controlled within appropriate thresholds and compliance with bank policy, ongoing monitoring is conducted by applicable first and second lines of defense within the bank. This includes:

• Annual NTTP Process: Ensuring policies, procedures, and processes are compliant with bank policy and regulations.
• Annual DDARA Process: Reviewing updated documentation to ensure Program Managers remain within the bank’s risk tolerance.
• Ongoing Control Testing: Conducted by Business Controls testing teams.
• Periodic Reviews and Audits: Conducted by Compliance and Internal Audit.

Risk Committee Oversight

Our risk governance structure ensures proper oversight of risk across the firm. This structure provides a clear path for escalating risks and issues to management and board-level committees, enabling effective risk decision-making.

Escalation of Significant Risks

Any significant risks and issues arising from the BIN Sponsorship Issuing Program should be escalated through our existing risk governance structure. This ensures proper oversight and timely remediation.

Annual Policy Review

The policy must be reviewed and approved annually by the Board of Directors. This review process involves the Management Compliance Committee, Enterprise Risk Management Committee, and Board Risk and Compliance Committee to ensure comprehensive oversight.