Existing Lines of Defence
Key weaknesses are often found in the traditional risk control mechanism within Treasury operations:
Treasurers – often have many other roles to play and may find it difficult to see key patterns developing.
Risk Management – in many organisations there is little crossover from front to middle-office resulting in a lack of front-office experience within the risk-management function.
Internal Audit - there are constraints on their effectiveness such as:
- the timing of their investigations tends to be predictable and their review process-led;
- in common with the risk management function they may only have limited experience of specialist front-office Treasury issues - particularly the subtle behavioural ones; and
- they are often only called upon when problems have already occurred.
External Audit – is normally provided by one of the “big four” firms and may be perceived to carry more gravitas, but can be hampered by similar issues:
- they can arrive long after the pattern has evolved into an entrenched problem;
- they are process-auditors making the review prone to being reactive; and
- there tends to be a high proportion of career consultants within their review teams.
The XMI Approach
The unique methodology for the Risk Control Programme was developed from extensive, hands-on experience and gets under the skin of the following:
Human Factor Risk - challenging and examining the behaviours and professional competencies of treasury staff;
People Management – scrutinising the people processes which create the foundations for an appropriate Treasury culture and working environment;
Treasury Strategy and Business Planning – examining linkages with corporate strategy and levels of “buy-in” from the Treasury area;
Market Risk – analysing the risk profile and its consistency with trading and sales objectives;
Control of Dealers – checking reporting lines, segregation of duties, the potential for trade manipulation, limit and mandate control;
Pricing - reviewing appropriateness of client and internal pricing policies;
Management Information – examining quality of data produced and effectiveness of how it is interpreted and disseminated.
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