CBS-4 Treasury & Capital Markets
Introduction
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.
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 |
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.

Gain Competency: For organisations looking to accelerate their journey, BCM Institute’s training and certification programs, including the OR-5000 Operational Resilience Expert Implementer course, provide in-depth insights and practical toolkits for effectively embedding this model.



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