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Operational Resilience Framework: A Case Study of AmBank Malaysia
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[OR] [AmB] [E3] [CBS] [4] [SuPS] Identify Severe but Plausible Scenarios

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Treasury & Capital Markets functions are inherently exposed to high-impact operational, market, and technology-driven risks due to their reliance on real-time trading systems, external market infrastructures, complex products, and strict regulatory obligations.

In line with the operational resilience principle of “severe but plausible scenarios”, this chapter identifies scenarios that test AmBank’s ability to continue delivering CBS-4 Treasury & Capital Markets services under extreme yet credible disruptions.

These scenarios go beyond traditional risk events and focus on service disruption, harm to customers, market integrity, and financial stability.

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Moh Heng Goh
Operational Resilience Certified Planner-Specialist-Expert

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Introduction

[OR] [AmB] [E3] [CBS] [4] [SuPS] Identify Severe but Plausible Scenarios

Treasury & Capital Markets functions are inherently exposed to high-impact operational, market, and technology-driven risks due to their reliance on real-time trading systems, external market infrastructures, complex products, and strict regulatory obligations.

In line with the operational resilience principle of “severe but plausible scenarios”, this chapter identifies scenarios that test AmBank’s ability to continue delivering CBS-4 Treasury & Capital Markets services under extreme yet credible disruptions.

These scenarios go beyond traditional risk events and focus on service disruption, harm to customers, market integrity, and financial stability.

Consistent with the guidance outlined in the BCM Institute blog “What are Severe but Plausible Scenarios in Operational Resilience”, the scenarios below integrate operational, cyber, ICT, third-party, and people risks, enabling AmBank to assess vulnerabilities, set impact tolerances, and strengthen end-to-end resilience across Treasury & Capital Markets value chains.

Banner [Table] [OR] [E3] Identify Severe but Plausible Scenarios

Table P5: Identify Severe but Plausible Scenarios for CBS-4 

Sub-CBS Code

Sub-CBS

Severe but Plausible Scenario

Impact / Effect

Proactive Risk Management Action

Link to Integration of Cyber and ICT Risks

4.1

Foreign Exchange (FX) Trading

Core FX trading platform outage during volatile market conditions due to a cyber intrusion

Inability to execute FX trades, client losses, market exposure, and reputational damage

Active-active trading platforms, dealer manual fallback procedures, and regular cyber penetration testing

Trading system cyber resilience, DDoS protection, and real-time SIEM monitoring

4.2

Interest Rate & Money Market Trading

Market data feed corruption from a third-party provider

Incorrect pricing, erroneous trades, and financial loss

Dual market data vendors, automated data validation controls

Third-party ICT risk assessment, data integrity controls

4.3

Derivatives & Structured Products

Unauthorized system access leading to the manipulation of derivatives valuation models

Mispricing, regulatory breach, client disputes

Strong access controls, model governance, segregation of duties

Privileged access management (PAM), cyber anomaly detection

4.4

Fixed Income & Debt Instruments Trading

Failure of the electronic trading platform during bond market stress

Trade execution delays, liquidity risk

Pre-approved voice trading fallback, alternate execution venues

Platform resilience testing, network redundancy

4.5

Capital Markets Origination & Syndication

Document management system unavailable during deal closing

Delayed issuance, client dissatisfaction, revenue impact

Secure offline document repositories, crisis playbooks

Secure document platforms, ransomware protection

4.6

Debt Capital Market (DCM) Solutions & Advisory

Loss of key deal team due to pandemic or coordinated cyber-physical incident

Advisory disruption, execution delays

Cross-trained teams, succession planning, and remote working readiness

Secure remote access, endpoint protection

4.7

Asset Liability & Balance Sheet Management (ALM)

ALM system failure during liquidity stress scenario

Inaccurate liquidity positions, regulatory breaches

Parallel ALM systems, spreadsheet-based contingency models

Core banking integration resilience, data backup integrity

4.8

Market Risk Analytics & Reporting

Market risk engine unavailable at regulatory reporting deadline

Late or inaccurate risk reports, supervisory action

Pre-run reports, manual calculation procedures

Risk engine cyber hardening, batch job monitoring

4.9

Post-Trade & Settlement Operations

Settlement system disruption due to a SWIFT-related cyber incident

Failed settlements, counterparty disputes, and financial penalties

SWIFT CSP compliance, alternate settlement arrangements

SWIFT security controls, transaction monitoring

4.10

Regulatory & Compliance Governance

Regulatory reporting platform compromised by malware

Data leakage, non-compliance, and enforcement actions

Immutable backups, regulatory reporting rehearsals

Malware protection, secure regulatory data transmission

4.11

Client Relationship & Sales Support

CRM system outage during market volatility

Client communication breakdown, reputational harm

Crisis communication protocols, manual client contact lists

CRM cyber resilience, cloud availability management

 Banner [Summing] [OR] [E3] Identify Severe but Plausible Scenarios

The identification of severe but plausible scenarios for CBS-4 Treasury & Capital Markets enables AmBank to move beyond traditional risk management and toward a service-centric operational resilience framework. These scenarios deliberately stress critical dependencies—technology, people, third parties, and data—under conditions that could realistically occur during market turbulence or systemic disruption.

By explicitly linking each scenario to proactive risk management actions and the integration of cyber and ICT risks, AmBank strengthens its ability to remain within impact tolerances, protect clients and market confidence, and meet regulatory expectations. This approach supports Bank Negara Malaysia’s operational resilience objectives and positions Treasury & Capital Markets as a resilient, well-governed, and trusted function even under extreme but credible disruption scenarios.

Operational Resilience Framework: A Case Study of AmBank Malaysia

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