[OR] [BI] [E3] [CBS] [2] [SuPS] Identify Severe but Plausible Scenarios

Written by Moh Heng Goh | Feb 16, 2026 5:45:15 AM

CBS-2 Payments and Funds Transfer Services

Introduction

For Bank Islam Malaysia Berhad, Payments and Funds Transfer Services (CBS-2) represent a mission-critical capability underpinning customer trust, liquidity flow, and regulatory compliance. In line with operational resilience principles, identifying severe but plausible scenarios enables the Bank to test its ability to remain within defined impact tolerances even under extreme stress conditions.

These scenarios are not routine operational incidents, but high-impact events that are credible within today’s threat landscape—ranging from cyber-attacks and ICT infrastructure failure to regulatory breaches and third-party disruptions. The table below maps each Sub-CBS to representative severe but plausible scenarios, outlines their impact, and demonstrates proactive risk management actions aligned with cyber and ICT risk integration.

Table P5: Identify Severe but Plausible Scenarios for CBS-2

Sub-CBS Code	Sub-CBS	Severe but Plausible Scenario	Impact / Effect	Proactive Risk Management Action	Link to Integration of Cyber and ICT Risks
2-01	Customer Payment Initiation	Distributed Denial-of-Service (DDoS) attack on internet/mobile banking channels during the peak period	Customers unable to initiate payments; reputational damage	DDoS mitigation services, traffic filtering, alternate channel routing, and customer communication protocol	Cybersecurity operations centre (SOC) monitoring, network resilience, secure digital channel architecture
2-02	Funds Transfer Processing (Intra-bank)	Core banking interface failure due to database corruption	Internal transfers delayed; account imbalance risk	Real-time database replication, automated failover, periodic recovery testing	ICT resilience, high-availability infrastructure, backup data integrity controls
2-03	Interbank Transfer Processing (IBFT & RENTAS)	National payment gateway outage affecting IBFT and RENTAS connectivity	Interbank transfers halted; liquidity and settlement delays	Contingency connectivity, manual fallback procedures, liquidity buffer planning	Third-party ICT dependency management, secure network connectivity, SWIFT/network redundancy
2-04	DuitNow & Instant Payment Services	Malware infiltration is affecting the instant payment API gateway	Fraudulent transactions; financial loss	API gateway hardening, endpoint detection and response (EDR), transaction anomaly detection	Secure API framework, cyber threat intelligence integration, and continuous vulnerability scanning
2-05	Payment Clearing & Settlement	Settlement file corruption before the clearing cycle	Incorrect clearing positions; regulatory breach	File validation controls, checksum verification, dual control approval	Secure file transfer protocol (SFTP), encryption, and ICT integrity monitoring
2-06	Corporate & Bulk Payment Processing	Ransomware attack on the bulk payment processing server	Corporate salary/vendor payments disrupted	Network segmentation, immutable backups, ransomware response playbook	Enterprise cybersecurity posture, backup isolation, and incident response orchestration
2-07	Cross-Border Payment Processing	Sanctioned country restriction update not reflected in system rules	Regulatory non-compliance; sanctions breach	Automated sanctions list updates, periodic rules validation testing	AML system integration, secure data feeds, ICT change management, and governance
2-08	Payment Authorization & Authentication	Compromise of the multi-factor authentication (MFA) system	Unauthorized payment approvals	Strong MFA configuration, adaptive authentication, and credential compromise monitoring	Identity & Access Management (IAM), privileged access management (PAM), cybersecurity monitoring
2-09	Sanctions Screening & AML Monitoring	Screening engine downtime during a high-volume transaction period	Transactions processed without screening; compliance breach	High-availability AML infrastructure, transaction queuing mechanism, and manual screening fallback	RegTech system resilience, secure database redundancy, and monitoring of screening logs
2-10	Transaction Posting & Core Banking Update	Core banking batch posting is delayed due to system overload	Customer balance discrepancies; complaints surge	Capacity planning, stress testing, performance monitoring dashboards	ICT capacity management, application performance monitoring (APM)
2-11	Exception Handling & Reversal Management	System logic error causing incorrect auto-reversals	Financial misstatement; reconciliation backlog	Change control testing, maker-checker validation, exception dashboards	Secure SDLC, system audit trails, and access control governance
2-12	Reconciliation & Nostro/Vostro Management	Failure in the reconciliation engine due to a corrupted settlement feed	Unreconciled items; liquidity exposure	Automated reconciliation alerts, daily exception reporting, contingency manual recon	Secure data exchange controls, system integrity checks
2-13	Customer Notification & Confirmation	SMS/email gateway outage during payment processing disruption	Customers are unaware of payment status; complaint escalation	Multi-channel notification redundancy, message queue monitoring	Third-party ICT vendor resilience assessment, API failover controls
2-14	Payment Reporting & Regulatory Submission	Regulatory reporting file not submitted due to system integration failure	Regulatory penalty; supervisory action	Pre-submission validation checks, reporting automation monitoring, and escalation matrix	Secure reporting interface, ICT integration testing, compliance system monitoring
2-15	Payment Channel Availability & Infrastructure Support	Data centre power failure affecting payment systems	Full payment service outage	Dual data centre architecture, disaster recovery (DR) site activation drills, RTO/RPO validation	Data centre resilience, DR orchestration, cyber-physical security integration

Identifying severe but plausible scenarios for CBS-2 enables Bank Islam Malaysia Berhad to move beyond theoretical risk assessments and into practical resilience validation. By linking each Sub-CBS scenario to proactive controls and explicit cyber and ICT risk integration, the Bank strengthens its ability to withstand high-impact disruptions while maintaining customer confidence and regulatory compliance.

This structured approach ensures that operational resilience is not treated as a standalone compliance requirement, but as a dynamic capability embedded within technology governance, cybersecurity posture, third-party oversight, and enterprise risk management—positioning the Bank to operate confidently even under extreme but credible stress conditions.

Implementing Operational Resilience for Bank Islam: Aligning with BNM and Global Best Practices
eBook 3: Starting Your OR Implementation
CBS-2 Payments and Funds Transfer Services
CBS-2 DP	CBS-2 MD	CBS-2 MPR	CBS-2 ITo	CBS-2 SuPS	CBS-2 ST

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