[OR] [BB] [E1] [C5] Identifying Critical Business Services

eBook 1: Chapter 5What Are the Critical Business Services (CBS) of Boost Bank When Implementing an Operational Resilience Program?

In Operational resilience, a Critical Business Service (CBS) is defined as a service provided by an organisation, or by a third party on behalf of the organisation, that if disrupted would either:

Cause intolerable harm to one or more of the organisation’s clients, or
Pose a risk to the soundness, stability, or resilience of the broader industry (such as the financial system or orderly market operations).

For a digital bank like Boost Bank — a Malaysian digital bank operating through its app and digital platforms — identifying CBS is a central step in designing and implementing an operational resilience program.

It enables the bank to focus on the services essential to its customers and the financial ecosystem, ensuring they are protected, continuously available, and rapidly recoverable under stress.

Purpose of the Chapter

This chapter aims to establish a clear understanding of what constitutes Critical Business Services (CBS) within Boost Bank’s operational resilience programme.

As a licensed Malaysian digital bank operating in a fully technology-enabled environment, Boost Bank delivers financial services that customers depend on daily for payments, savings, lending, and digital financial access.

Disruptions to these services can result in significant customer harm, regulatory consequences, and broader financial system instability.

By defining CBS in line with operational resilience principles and regulatory expectations — including Bank Negara Malaysia’s (BNM) evolving Operational Resilience framework and Risk Management in Technology (RMiT) requirements — this chapter provides the foundation for prioritising resilience efforts where they matter most.

By the end of this chapter, readers are expected to understand how to identify and articulate Boost Bank’s Critical Business Services, distinguish them from supporting operational processes, and appreciate the regulatory rationale behind CBS identification.

Readers will also gain clarity on how CBS mapping enables the setting of impact tolerances, dependency analysis, scenario testing, and governance oversight — all of which are essential components of a robust operational resilience programme for a Malaysian digital bank.

Critical Business Services (CBS) of Maybank Investment Bank

CBS Code	Critical Business Service (CBS)	Description of Service	Why It Is Critical (Customer / System Impact)	Key Regulatory Considerations (BNM Context)
CBS-1	Digital Account Access & Management	Customer ability to access accounts, view balances, manage savings jars, and perform account maintenance via mobile app	Loss of access prevents customers from viewing or managing funds, causing immediate customer harm and reputational damage	RMiT requirements on system availability, cybersecurity controls, and incident reporting; Operational Resilience expectation to maintain critical financial services
CBS-2	Payments & Fund Transfers (Interbank & P2P)	Real-time transfers, DuitNow/IBG/instant transfers, peer-to-peer payments	Payment disruptions can cause financial hardship, merchant impact, and loss of public confidence in digital banking	BNM expectation to maintain stability of payment services; operational resilience focus on maintaining critical financial functions
CBS-3	Deposit & Withdrawal Services	Processing inbound deposits and enabling withdrawals (including ATM/debit card-linked access)	Inability to access funds directly harms customers and may trigger systemic confidence issues	Prudential and liquidity oversight; resilience of core banking systems and payment connectivity
CBS-4	Debit Card Transaction Processing	Card authorisation, clearing, and settlement services	Failed card transactions affect daily living needs (retail, fuel, transport) and damage trust in digital banking	RMiT (technology resilience, third-party risk); card network dependency management
CBS-5	Digital Lending & Credit Disbursement	Loan origination, approval, and disbursement (e.g., microloans, term loans)	Disruptions delay access to credit and may breach contractual or regulatory obligations	Credit risk governance; system integrity and data accuracy requirements
CBS-6	Customer Authentication & eKYC	Identity verification, login authentication, onboarding processes	System failure prevents new customer onboarding and blocks access to all digital services	RMiT cybersecurity controls; data protection compliance; fraud risk mitigation
CBS-7	API & Ecosystem Integration Services	Integration with Boost ecosystem, payment rails, and third-party service providers	Failure disrupts interconnected services, potentially affecting a large user base beyond direct banking customers	Third-party risk management under RMiT; dependency mapping required under operational resilience framework
CBS-8	Incident Response & Customer Support Channels	Communication, complaints handling, and incident management during service disruption	Poor response during outages amplifies harm and regulatory scrutiny	Governance and accountability expectations under BNM operational resilience direction

Underpinning Operational Components

Identifying CBS also requires understanding the dependencies and “underpinning services” that support them, such as:

Core banking systems and databases
Cloud hosting, network infrastructure, and data centres
Third-party service providers and outsourced operators
Cybersecurity and incident detection tools
These dependencies must be mapped to understand how disruptions propagate and to set appropriate impact tolerances.

Regulatory Expectations in Malaysia

Bank Negara Malaysia (BNM), Malaysia’s central bank and financial regulator, is advancing operational resilience requirements for financial institutions, including digital banks like Boost Bank.

BNM Discussion Paper on Operational Resilience (2025)

In December 2025, BNM issued a discussion paper outlining its emerging regulatory direction on operational resilience for financial institutions. Though still consultative pending final policy issuance, it emphasises:

Maintaining critical financial services during stress as essential to preserving public confidence and financial stability.
Resilience governance and accountability mechanisms, tailored to increasingly digitalised, interconnected operations.
Focus on ability to prevent, respond, recover, and adapt to disruptions across people, processes, technology, and third-party relationships.

This reflects an evolution in BNM’s supervisory expectations, complementing existing risk and continuity frameworks.

Existing Regulatory Frameworks with Resilience Implications

While BNM’s dedicated operational resilience policy is forthcoming, related regulatory instruments currently reinforce resilience requirements:

Risk Management in Technology (RMiT) — a BNM policy that mandates governance, cybersecurity controls, third-party risk management, incident reporting, and resilience measures for technology systems. The RMiT requirements are particularly relevant for digital banks that depend heavily on technology platforms and third-party outsourced solutions.
Business Continuity Management (BCM) Expectations — through BNM’s supervisory framework, BCM policies require financial institutions to conduct business impact analyses, have recovery strategies, and ensure continuity of essential services.

Impact on Boost Bank

As a licensed digital bank, Boost Bank is required to demonstrate operational readiness (as part of its licensing and ongoing supervision).

Its regulatory approval from BNM and the Ministry of Finance was contingent on a “thorough operational readiness review,” which implicitly requires robust infrastructure and resilience capabilities, including those supporting CBS.

Operational Resilience Implementation: CBS Lens

For Boost Bank to operationalise resilience around CBS, it should:

Identify and Document CBS
Clearly map service flows and dependencies for core banking, payments, lending, and ecosystem integration.

Conduct Business Impact Analysis (BIA)
Establish impact tolerances — the maximum acceptable disruption duration or loss thresholds for each CBS.

Configure Resilience Capabilities
Embed redundancy, failover, disaster recovery, cybersecurity controls, and continuity playbooks for critical systems.

Test and Validate
Run scenario tests and simulations to gauge service resilience under stress and refine plans accordingly.

Governance & Reporting
Implement governance structures that align with BNM expectations for resilience oversight.

Embedding Resilience through Critical Business Services

Identifying and managing Critical Business Services is central to Boost Bank’s operational resilience program.

For a digital bank operating in Malaysia’s evolving regulatory environment, CBS not only support internal continuity objectives but also aligns with BNM’s emerging resilience expectations.

Through robust identification, dependency mapping, impact tolerance setting, and structured resilience planning, Boost Bank can strengthen its capacity to withstand and adapt to service disruptions — safeguarding customers, the organisation, and the broader financial system.

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Digital Banking Resilience: Strengthening Boost Bank for Tomorrow
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