A multinational bank's board has set a low risk appetite for regulatory compliance failures. The CGEIT practitioner discovers that a critical IT system supporting anti-money laundering (AML) reporting is running on an unsupported operating system. The IT director argues that upgrading is too costly and proposes compensating controls. Which action should the practitioner recommend to the board?
The board needs a comprehensive risk analysis to make an informed decision aligned with its low risk appetite. Quantifying the compliance exposure—such as potential fines, sanctions, and reputational harm—and evaluating options like upgrading, compensating controls, or replacement provides a balanced view. This approach respects the board's role in risk oversight and ensures that the decision is based on accurate information. It also documents due diligence, which is essential for regulatory accountability.
Why this answer
With a low risk appetite for compliance failures, the board must be presented with a thorough risk analysis that quantifies exposure and evaluates all viable options. This enables an informed decision that balances risk reduction with cost and operational considerations. The analysis should include the likelihood and impact of regulatory penalties, the effectiveness of compensating controls, and the feasibility of upgrade or replacement.
This approach ensures the board exercises proper oversight and documents its rationale, which is crucial for regulatory accountability.
Exam trap
The trap here is assuming that compensating controls alone are sufficient for a low risk appetite, without quantifying residual risk and presenting options to the board.