Risk Management and Capacity Development
Risk Management and Capacity Development:
Risk Associated with General Banking:
Risk is the uncertainties of happening the expected result. Every business organisation involves some risk. Without risk possibly there being no business. In banking business there
is also a good number of risks. The bank exists to take on the risks of its customer base.
Bank’s primary expertise stems from their ability both to measure and manage risk exposure on their own behalf and on behalf of their clients. As such in all levels of bank officials must
have a clear understanding about the related risks and their mitigational tools in general banking operations.
Objective of risk management is to identify and analyze risks and manage their consequences. Basel II Accord, the standards of Risk Management as guided by the Bank for International Settlements (BIS) and bank regulators have applied particularly Basel Committee on Banking Supervision (BCBS), across the world. Bangladesh Bank also issued guidelines, which forms the basis of risk management of the banks in Bangladesh.
The guidelines require that the banks adopt enhanced policies and procedures of risk management. Risk management strategy in NCCBL should base on a clear understanding of various risks, disciplined risk assessment, measurement procedures and continuous monitoring. It should also focus on improving its risk management systems not only to ensure compliance with regulatory requirements but also to ensure better risk-adjusted return and optimal capital utilization keeping in mind of the business objectives. For sound risk management, NCCBL try to manage risk in strategic layer, managerial layer, and operational
Operational risk is involved in all the activities of the banking business. Particularly in general banking there is also operational risk. But in practice the following risks are directly
involved in general banking.
Legal Risk: The risk of the unexpected application of a law or regulation, usually resulting in a loss. Legal Risks are categorized as under:
a. Compliance with legislation: The risk that the management fails to implement legislative or regulatory requirements.
b. Contracts: The risk that arises due to contractual failure.
c. Litigation risk: Risk associated with existing and potential litigation due to procedural lapses.
Fraud Risk: Risk arises due to improper personal gain or loss of assets through deliberate misrepresentation, deceit or deception. Fraud Risk arises due to the following cases:
1. Financial Instruments
2. Fraudulent Financial Reporting
3. Misappropriation of Assets
4. Assets gain for fraudulent or illegal activities
5. Other misconduct
Money Laundering Risk: Money Laundering means properties acquired or earned directly or indirectly through illegal means or illegal transfer, conversion and concealment of
location. Bangladesh Bank through BRPD Circular No. 17 dated October 07, 2003 advised the scheduled commercial banks operating in the country to put in place effective risk
management system which includes Money Laundering Risk Management among others.
The bank has to update Anti Money Laundering Guidelines, which should include Senior Management commitment to the anti-money laundering program.
The Management should also evolve such a culture for the bank so that all the employees strictly adhere to each and every provision of Money Laundering Prevention Act 2012 and
Anti-Terrorism Act-2009 with amendment of 2013. All employees of the Bank, irrespective of the position they hold, are accountable to the top management and regulatory body for their activities which might directly or indirectly relate to money
laundering. For effective management of money laundering, all employees of the bank should follow the Money Laundering Prevention Act, 2012 and the detailed guidelines of the
bank as well.
Note: As regards combating money laundering and terrorist financing of the commercial banks, a circular number 19 dated September 17, 2017 of BFIU are placed in annexure-16
Process Risk: It is the risk which arises due to lack of knowledge, inefficiency, violations of circular /instruction or using of obsolescence existing procedures.
Compliance Risk: Compliance risk arises due to failure to comply with any or all of the applicable laws, regulations, code of conduct, regulatory standards and usual good principles
Ethical Risk: Ethical Risk arises because of not having distinction between right and wrong, good and bad, just and unjust, virtues and vice and also lack of having morality, dishonesty and also making discrimination in their banking activities.
System Risk: This risk arises due to loss of use or functionality of information systems or the integrity of data.
Reputation Risk: Reputation risk comes from negative public opinion. This risk may leads to trial, financial loss, or a decline in customer base for the institution.
Internal Control and Compliance (ICC) Risk: Internal Control and Compliance is a management process designed to achieve effectiveness and efficiency of operations, reliable financial reporting and compliance with laws and regulations. A robust Internal Control and Compliance System of the bank will help to mitigate the possible risks that may arise in general banking. Management Committee (MANCOM) of the bank is expected to review the overall effectiveness of internal control system.
Strategic Risk: Strategic risk arising from adverse business decisions, improper implementation of decisions, or lack of responsiveness to industry changes.
Detection Risk: The risk that the auditor will not detect a material misstatement that exists in the financial statements. The auditor through the scope of the audit procedures performed can control detection risk.
Cultural Risk: There are many misunderstandings that can occur in business transactions negotiated among different domestic areas and cross border countries in distant time zones,
with different languages, varying cultural practices and dissimilar ethical values.
Management Risk: The risks associated with ineffective, destructive or underperforming management of the organization.
Communication Risk: Communication risk arises due to the failure of internal/external communications or relationship management processes.
Documentation Risk: It is the risk that created a probability of loss that a legal agreement may turn out to be incomplete, insufficient or otherwise unenforceable.
Competence risk: Competence risk is the risk which arises due to insufficient training, skills, experience and knowledge which cause to the inability of the employee to perform
their job efficiently and effectively.
Importance of Risk Management in General Banking
Establishing sound risk management is the responsibility of banks’ management. An effective risk management system requires identifying, measuring and limiting risks involved in general banking which depends on appropriate internal control and compliance procedures of the bank. Effective risk management helps to derive the following benefits:
1. Increases overall productivity of the bank
2. Balance cost effectiveness
3. Increase profitability
4. Improve service quality
5. Maintain reputation
6. Retain Brand Value
7. Improve earning quality
8. Increase customer base
9. Increase knowledge base
10. Increase efficiency and confidence level of the employees
Risk Control and Management:
Policies, Standard Operating process, Manuals, circulars, instructions, system and network Procedures in regard to general banking should be in place and implementation
of those are to be regularly monitored.
Internal Audit & Inspection and Internal Control and Compliance Division of the bank should undertake periodical comprehensive and special audit of branches for review of
the general banking related operational procedures and their compliance The Audit Committee of the Board subsequently would have reviewed the reports of the Internal Control and Compliance Division.
Segregation of duties and multi-tier checking and approval procedure are to be in place,
IT Audit is to be carried out on regular basis
Data Center for backup of data and information has to be established.
Regular testing of system’s back-up procedure and contingency plan are to be made.
Monitoring and Reporting:
The overall management of the general banking operations to be monitored on an ongoing basis for effectiveness of the bank. Monitoring of key risks should be the part of the daily
activities of the bank as well as periodic evaluations by the business lines and internal audit.
Reporting of the activities is one of the important issues of risk management. It may betreated as the mirror of the organization as to the fact what actually happening in the activities that are being carried out by the bank. Accuracy of the report is a vital one, as because decisions are expected to be made based on reliable, dependable and correctness of the facts. In general banking operations, monitoring and proper reporting by the line
business is quite significant to prevent any operational loss. The higher authority as well as the MANCOM is supposed to be very vigilant in this regard also.
The Bank will have a performance-driven rewarding work culture; where employees are treated with respect and receive widened opportunities to realize their diverse Learning
& development opportunities. Bank should continuously thrive to transform Human Resources to Human Capital through appropriate learning and development initiatives in
every aspects of the work area. HR Division regularly should undertake effectively designed general banking related training programs targeting the right group of employees through proper training need assessment. Effectively designed program will
provide ample opportunities to acquire necessary knowledge, skills, attitude and on-thejob-experience of the bank that will ultimately help to increase the capacity development
of the bank employees.
The Bank has to acknowledge that Succession Planning and Management is vital to the continued success of the Bank. So, the Bank continuously should assess organizational, divisional and team capability gaps to identify, develop and retain the successors in a timely manner to meet the demands of the future. To ensure a proper performance evaluation and rate the employees based on their comparative performance, the line
Management is guided by the Human Resources Division. This performance appraisal system is considered as crucial for the Bank as this is a very important tool to identify and distinguish the performers and non-performers. Bank should believe that a wellexecuted performance appraisal system can help to reward the deserving employees, as well as help to ensure further development program for the rest. The comprehensive
performance management also includes an assessment of employees’ functional and leadership competencies. This appraisal process will help to identify the competency gap
and training needs of employees in general banking.
Capacity Development (CD) Banks can bring about a change in their operational activities through Capacity Development to a great extent. Capacity Development is a change process. It can entail change of knowledge, skills, work processes, tools, systems, authority patterns, management style, etc. CD takes place in people or organizations, and, like learning, it cannot be forced upon them. People and organizations can have strong or weak incentives to change, develop, and learn—but eventually the change is an internal process that has to happen in the people or organizations changing.
Capacity development needs for the dissatisfaction with the present situation and where it requires the change of knowledge, skill development through learning and training and also
developing the procedures to perform the desired activities of the organization. If change management is poor or poorly prioritized, then the hope of getting to a better future quickly
fades, even if everybody can see how much better capacity and performance could become.
Capacity development is essentially required for the employees of the bank who will especially involved in general banking, of course, if the management so desires.
Knowledge Management (KM):
A bank can also create their capacity development in general banking through Knowledge Management also. Knowledge management is becoming very important in almost all banks
since it simplifies the delivery of timely and effective information. It helps managers in formulating strategic, tactical and operational activities in the best ways in order to achieve
KM can lead to many organisational benefits like better solution to problems and decisionmaking, improved customer services, increasing profits, better stuff attraction, more innovation and greater creativity. The process becomes essential and banks assign specialized personnel to watch over and manage these critical processes of KM.
The most common fields of KM applications in a bank are risk management, marketing management, customer relationship management and performance measurement. Nowadays
modern banks investigate the importance of the value of KM in the banks’ business practices.
The knowledge covers the range from the bank’s own internal intellectual capital to the wealth of data on customer transactions. For a bank, the implicit knowledge is very
important which is rarely recorded and transferred. The level of implicit knowledge depends upon several factors that include task knowledge, expertise knowledge, and level of training.
Knowledge must be made available in a useful format to anyone in the organization, who needs it, anywhere and anytime which is known as Knowledge Dissemination in a KM system.
Banks in Bangladesh generally do not have any formal KM strategies or KM system.
However, banks have some sort of arrangement for knowledge creation, storing, and dissemination. These KM functions are performed by the training institutions/centers of the
banks. Bangladesh Bank Training Academy (BBTA), the training wing of the central bank of the country, has a reasonably good training infrastructure to facilitate training, workshops
and seminars. To promote training facilities in banks, Bangladesh Bank has a guideline related to training infrastructure of banks. All banks in the country have training
institutes/wing and have budget allocations for training purposes.
A good number of banks have started using e-learning to train their employees for disseminating knowledge. Some banks also send their employees outside the country to obtain training.
Formulating and enforcing a ‘KM Strategy’ by banks is a need of the time in the country for better banking services and improved operation. In case of general banking capturing up-todate knowledge, storing it and its application are crucial for handling new banking challenges.
Corporate Governance in Banks:
Corporate governance is gaining centre stage in the recent times due to failure of corporate and wide dissatisfaction among the people with the way corporate works and hence became
a widely discussed topic worldwide. Corporate Governance is now recognized as a paradigm for improving competitiveness and enhancing efficiency and thus improving investors’
confidence and accessing capital. Now corporate governance has become a more dynamic concept and not a mere static one. Bank and Financial Institutions are the backbone of the economic sector of any country. The healthy economic condition of a nation is depicted through the sound functioning of its banks.
Banks form a crucial link of a country’s economic sector and hence they are universally regulated industry and their wellbeing is imperative for the economy. Working of banks is different from other corporate in many important respects, and that makes corporate governance of bank not only different but also critical. Hence corporate governance is conceptually different for banks. If a corporate fails, the fall outs can be restricted to the
stakeholders, but if a bank fails, the impact can spread rapidly through other banks with potentially serious consequences for the entire financial system and the macro economy.
Thus though various guidelines are provided for working of a bank, corporate governance cannot be overlooked or discarded. Regulations, guidelines and corporate governance are
complementary to each other in banking industry.
Questions and Answer Indications:
1. Define Legal Risk and Fraud Risk. (9.1)
2. What is Money Laundering? (9.1)
3. How process risk and compliance risk arises? (9.1)
4. What is ICC risk? (9.2)
5. What is the use of risk management? (9.3)
6. How risks control and management can be made in banks. (9.4)
7. How human capital can be better utilize for bank performance. (9.5)
8. Discuss about knowledge management. (9.5)