Scenario testing is a critical component of operational resilience,
In line with the principles outlined in BSP Circular No. 1203 (2024), financial institutions are expected to conduct forward-looking scenario testing to assess end-to-end service resilience, including interdependencies among people, processes, technology, and third parties.
This section translates those regulatory expectations into practical, process-level scenario testing for each Sub-CBS. The scenarios incorporate cyber threats, ICT disruptions, third-party failures, operational breakdowns, and fraud events, ensuring strong alignment with the integration of cyber and ICT risk management.
Each test also includes evidence of proactive risk management actions, demonstrating the bank’s ability not only to respond, but to anticipate and mitigate disruptions.
|
Sub-CBS Code |
Sub-CBS |
Recommended Scenario Test Themes |
Impact / Effect |
Evidence of Proactive Risk Management Action |
|
1.1 |
Customer Onboarding & Account Opening |
Digital onboarding system outage due to cyberattack (DDoS) |
Inability to open accounts; customer dissatisfaction |
Load testing, alternate manual onboarding, and DDoS protection tools implemented |
|
1.2 |
Customer Identity Verification & Compliance Screening |
Failure of the e-KYC system / third-party verification API outage |
Delayed onboarding; regulatory compliance risk |
Redundant KYC vendors; offline verification procedures; AML escalation protocols |
|
1.3 |
Account Setup & Product Configuration |
Core banking configuration error during system upgrade |
Incorrect account features; financial misstatements |
Pre-deployment testing, rollback procedures, maker-checker controls |
|
1.4 |
Initial Funding & Deposit Acceptance |
Payment gateway disruption affecting deposit channels |
Failed deposit transactions; customer complaints |
Multi-channel deposit options; real-time monitoring dashboards |
|
1.5 |
Cash Withdrawal & Funds Access |
ATM network outage due to telecom failure |
Customers are unable to withdraw cash |
ATM network redundancy; branch fallback; liquidity buffers |
|
1.6 |
Account Maintenance & Customer Information Update |
Unauthorised data change due to cyber intrusion |
Data integrity compromise; reputational damage |
Access controls, audit logs, anomaly detection systems |
|
1.7 |
Credential Fulfilment |
Card production vendor disruption |
Delayed issuance of cards/credentials |
Multiple vendors; inventory buffer; SLA monitoring |
|
1.8 |
Digital Banking Access Management |
Mobile banking platform outage (cloud failure) |
Customers are unable to access accounts |
Multi-region cloud deployment; failover testing |
|
1.9 |
Balance Inquiry & Statements |
Database performance degradation |
Slow response times; poor customer experience |
Database optimisation; caching; performance stress testing |
|
1.10 |
Account Transfers |
Real-time payment system failure (InstaPay/PESONet disruption) |
Failed transfers; liquidity bottlenecks |
Alternate clearing channels; transaction queuing mechanisms |
|
1.11 |
Bills Payment & Scheduled Debits |
Third-party biller system outage |
Missed payments; customer penalties |
Biller redundancy; customer notification protocols |
|
1.12 |
Transaction Posting & Ledger Update |
The core banking system crashed during peak hours |
Transaction backlog; reconciliation issues |
High availability architecture; batch recovery procedures |
|
1.13 |
Interest, Fees & Charges Processing |
Batch job failure due to a system bug |
Incorrect interest or fees applied |
Automated reconciliation checks; parallel run validation |
|
1.14 |
Exception Handling & Dispute Resolution |
Surge in disputes due to a fraud incident |
Operational overload; delayed resolution |
Scalable case management system; surge staffing plans |
|
1.15 |
Fraud Monitoring & Protective Controls |
Sophisticated cyber fraud bypassing detection systems |
Financial loss; regulatory breach |
AI-driven fraud analytics; continuous rule tuning; red team testing |
|
1.16 |
Reconciliation & Financial Reporting Support |
Data mismatch between systems |
Financial reporting inaccuracies |
Automated reconciliation tools; exception thresholds |
|
1.17 |
Regulatory Reporting & Compliance Monitoring |
Failure to submit regulatory reports on time due to a system outage |
Regulatory penalties; compliance breach |
Backup reporting systems; regulatory calendar tracking |
|
1.18 |
Service Continuity & Incident Response |
Data centre outage (natural disaster scenario) |
Full service disruption |
Disaster recovery site activation; crisis management drills |
|
1.19 |
Dormancy, Restriction & Closure |
Erroneous account freezing due to a system error |
Customer complaints; legal exposure |
Dual authorisation controls; audit review mechanisms |
|
1.20 |
Third-Party & Infrastructure Dependency Management |
Critical vendor (cloud/telecom) failure |
System-wide disruption |
Vendor risk assessments; exit strategies; multi-vendor architecture |
Scenario testing for CBS-1 Retail Deposit & Account Services enables BDO Unibank to move beyond theoretical resilience into demonstrated operational capability under stress.
By systematically testing each Sub-CBS against severe but plausible disruptions, the bank ensures that its services remain within the impact tolerances defined in BSP Circular 1203, even amid complex, multi-layered failures.
Importantly, integrating cyber and ICT risks into every scenario reflects the evolving threat landscape, in which operational disruptions are increasingly technology-driven.
The inclusion of evidence of proactive risk management further demonstrates maturity—showing that resilience is not only about recovery but also about anticipation, prevention, and continuous improvement.
This structured approach positions BDO Unibank to achieve a sustainable, regulator-aligned operational resilience capability.
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Building Operational Resilience: A Case Study of BDO Unibank |
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| eBook 3: Starting Your OR Implementation |
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| CBS-1 Deposit & Account Services | |||||
| CBS-1 DP | CBS-1 MD | CBS-1 MPR | CBS-1 ITo | CBS-1 SuPS | CBS-1 ST |
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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