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Operational Resilience in Practice: The Chinabank Approach
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[OR] [CBC] [E3] [CBS] [1] [MD] Map Dependency

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For CBS-1 Deposit and Account Services, dependency mapping should show not only the sequence of activities, but also the people, processes, technologies, and third parties that must work together to keep the service available during disruption.

The BCM Institute’s guidance on mapping interconnections and interdependencies emphasises that operational resilience mapping should identify dependencies across people, processes, information, technology, facilities, and third-party service providers so that vulnerabilities can be understood before disruption occurs.

BSP Circular No. 1203 takes the same direction by requiring BSFIs to map the chain of activities supporting critical operations, understand interconnections and interdependencies, and use that understanding to identify and address vulnerabilities.

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Moh Heng Goh
Operational Resilience Certified Planner-Specialist-Expert

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Introduction

For CBS-1 Deposit and Account Services, dependency mapping should show not only the sequence of activities, but also the people, processes, technologies, and third parties that must work together to keep the service available during disruption.

The BCM Institute’s guidance on mapping interconnections and interdependencies emphasises that operational resilience mapping should identify dependencies across people, processes, information, technology, facilities, and third-party service providers, enabling vulnerabilities to be understood before disruption occurs.

BSP Circular No. 1203 takes the same direction by requiring BSFIs to map the chain of activities supporting critical operations, understand interconnections and interdependencies, and use that understanding to identify and address vulnerabilities.

For China Banking Corporation (Chinabank), this mapping is especially relevant because deposit and account services are delivered through a mix of branches, ATMs, self-service channels, My CBC App, and Chinabank Online.

Chinabank states that as of December 31, 2024, it operated 650 branches and 1,081 ATMs, alongside its digital channels, and notes its membership in BancNet.

That operating model means CBS-1 depends on coordinated frontline operations, core banking processing, channel integration, fraud controls, reconciliation, compliance routines, and recovery arrangements across internal and external parties.

Banner [Table] [OR] [E3] Map Dependency

Table P2: Map Dependency for CBS-1

Sub-CBS Code

Sub-CBS

Dependency Type

Dependency Detail (What/Who is involved)

Connectivity (How it connects/interacts with the CBS or other components)

1.1

Customer Onboarding & Account Opening

People

Branch sales staff, relationship managers, customer service officers, and digital onboarding support team

They initiate account requests, explain product options, capture customer data, and hand over applications to KYC/CDD and approval workflows.

   

Process

Product selection, account application intake, document capture, consent collection, and initial screening

Starts the end-to-end deposit service chain and feeds customer information into KYC/CDD, approval, and account creation.

   

Technology

Branch onboarding workstation, digital forms, document capture tools, workflow/case management platform, website/mobile onboarding interface

Connects customer-facing channels to back-office review and core account-opening processes.

   

Third Party

ID validation utilities, courier/document collection providers, telecom/network providers

Support remote application, transmission of documents, and connectivity for branch and digital onboarding.

1.2

Customer Identity Verification & Compliance Screening

People

Compliance officers, branch operations staff, AML analysts, and onboarding reviewers

They verify identity, screen customer risk, validate documents, and decide whether the account can proceed to approval.

   

Process

Identity verification, sanctions/PEP screening, customer due diligence, risk classification, exception escalation

This process determines whether onboarding can proceed and directly gates account approval and opening.

   

Technology

KYC screening engine, sanctions watchlist tools, customer information file, document repository, case management system

Interfaces with onboarding, compliance, fraud monitoring, and customer master records to establish a verified customer profile.

   

Third Party

Watchlist/data providers, government or external identity data sources, managed compliance services, where used

Provide reference data and screening inputs needed to satisfy AML/CFT and customer due diligence requirements.

1.3

Account Setup & Product Configuration

People

Approvers, branch managers, operations control staff, and compliance reviewers for exceptions

They review completed onboarding/KYC results and authorise account creation based on delegated authority.

   

Process

Approval workflow, account number generation, product code assignment, CIF linking, maker-checker control

Converts a validated application into a live account and passes the record to funding, servicing, and reporting processes.

   

Technology

Core banking platform, approval workflow engine, CIF master database, parameter tables

Establishes the official account record that downstream teller, ATM, online, and reconciliation processes will use.

   

Third Party

Network and infrastructure providers, outsourced printing or card/passbook vendors,  where applicable

Enable related fulfilment activities once the account is activated.

1.4

Initial Funding & Deposit Acceptance

People

Teller staff, branch operations, treasury/settlement support, customer service personnel

They receive initial deposits, verify source/funding instructions, and ensure balances are posted correctly.

   

Process

Cash acceptance, cheque acceptance, internal transfer funding, posting and validation, receipt issuance

Activates the usable deposit relationship and feeds balances into interest, reporting, and access channels.

   

Technology

Teller platform, cash transaction system, cheque capture/clearing interface, core ledger

Connects funding events to the customer account balance and transaction history.

   

Third Party

Clearing/payment network participants, cash logistics providers, telecom/network service providers

Support transaction routing, cheque clearing, and secure transmission of funding instructions.

1.5

Cash Withdrawal & Funds Access

People

Product managers, operations administrators, system support staff, and authorised maintenance officers

They define and maintain product rules, interest tables, fees, limits, and account status controls.

   

Process

Parameter setup, maintenance approval, periodic updates, exception handling, and audit trail review

Determines how the account behaves across transactions, fees, statements, channel access, and regulatory controls.

   

Technology

Core product parameter tables, configuration management tools, and reference data systems

Supplies the business rules used by transaction processing, interest accrual, statements, and digital channels.

   

Third Party

Vendor-supported banking applications, managed configuration support where used

May support system changes, patching, or controlled updates to parameter-driven products.

1.6

Account Maintenance & Customer Information Update

People

Tellers, branch operations staff, digital banking operations team, transaction support staff

They execute and monitor routine deposit credits, transfers, and account postings.

   

Process

Cash deposit, cheque deposit, transfer crediting, transaction validation, posting, balancing

Keeps deposit accounts current and connects with reconciliation, fraud monitoring, and customer reporting.

   

Technology

Core transaction engine, branch teller system, ATM/switch integration, online/mobile banking interfaces

Enables transactions to be accepted through branch, ATM, and digital channels and posted to the core account.

   

Third Party

BancNet, payment/clearing counterparties, telecom providers, ATM support providers

Extend transaction reach across shared networks and support continuous channel availability.

1.7

Passbook, Debit Card, Chequebook & Credential Fulfilment

People

Tellers, branch supervisors, ATM/channel support staff, fraud operations team

They authenticate withdrawal requests, authorise exceptions, and manage unusual or high-risk transactions.

   

Process

Cash withdrawal, over-the-counter debit, ATM cash-out, transfer-out validation, limit checking

Directly affects customers’ ability to access funds and depends on the integrity of balances, authentication, and fraud controls.

   

Technology

Core banking ledger, ATM switch, debit authentication controls, mobile/online authorisation engine

Links real-time balance validation with customer channels to permit or deny access to funds.

   

Third Party

BancNet, ATM hardware/service providers, telecom carriers, cash replenishment vendors

Support external network connectivity, ATM operation, and physical cash availability.

1.8

Digital Banking Access Management

People

Customer service officers, call centre staff, branch operations, maintenance approvers

They process changes to customer profiles, contact details, mandates, account status, and service requests.

   

Process

Data update, account reactivation/dormancy handling, signature update, dispute/request management

Ensures account records stay accurate and usable across transactions, statements, compliance, and digital access.

   

Technology

Customer master file, CRM/service request tools, document archive, core maintenance screens

Propagates updated customer/account data across the servicing ecosystem.

   

Third Party

Call centre service partners, document archiving vendors, and telecom providers

Support customer interaction and secure communication for servicing requests.

1.9

Balance Inquiry, Statement & Account Information Services

People

Product operations staff, finance controllers, system support analysts

They validate accrual rules, monitor fee runs, and resolve rate or charge anomalies.

   

Process

Interest accrual, fee assessment, withholding tax handling, reversal/correction routines

Affects customer balances, statements, complaints handling, and financial/regulatory reporting.

   

Technology

Core banking batch engine, rate tables, fee rules engine, finance/reporting interface

Applies product parameters to account balances and sends outputs to statements and general ledger processes.

   

Third Party

Tax/reference data providers were used, vendor-supported core systems

Support correct computation and timely batch execution in the presence of external dependencies.

1.10

Internal & External Account Transfers Linked to Deposits

People

Branch servicing staff, operations reporting team, contact centre staff, statement production team

They respond to balance inquiries, update passbooks where applicable, and manage statement generation and delivery issues.

   

Process

End-of-day balance consolidation, statement generation, passbook update, customer notification, dispute handling

Converts posted account activity into customer-visible records and evidence of account servicing.

   

Technology

Statement generation platform, document composition tools, core ledger extract, online banking display layer

Pulls transaction and balance data from the core system into the branch, print, email, and digital presentation channels.

   

Third Party

Printing/mailing vendors, email/SMS gateway providers, and courier services

Enable delivery of account information through physical and electronic channels.

1.11

Bills Payment & Scheduled Debit Services

People

Digital banking team, channel operations staff, cybersecurity team, and customer support

They manage customer access, channel performance, incident handling, and user support across digital services.

   

Process

User authentication, session management, channel availability monitoring, API/interface management, customer self-service

Connects deposit accounts to My CBC App, Chinabank Online, ATM access, alerts, and self-service functions.

   

Technology

My CBC App, Chinabank Online, ATM/channel switch, API gateway, IAM/authentication controls, monitoring tools

Serves as the front-end access layer to balances, transfers, account servicing, and transaction confirmation.

   

Third Party

BancNet, telecom carriers, internet providers, and cloud/managed security providers were used

Extend channel connectivity and authentication resilience beyond the bank’s internal environment.

1.12

Transaction Posting & Ledger Update

People

Operations control staff, finance reconciliation team, branch balancing officers, exception analysts

They compare records, investigate breaks, and escalate unresolved discrepancies.

   

Process

Daily balancing, suspense management, unmatched item investigation, correction posting, escalation

Protects the integrity of balances across deposit processing, ATM/digital channels, statements, and regulatory reporting.

   

Technology

Reconciliation engine, suspense account reports, general ledger interface, exception workflow tracker

Pulls data from core banking, channels, and settlement sources to identify inconsistencies.

   

Third Party

Network settlement reports, correspondent/payment partners, and outsourced reconciliation support were used

Supply external records required to verify transaction completeness and accuracy.

1.13

Interest, Fees & Charges Processing

People

Fraud analysts, AML monitoring staff, cybersecurity analysts, operations investigators

They review alerts, validate suspicious activity, block or challenge transactions, and escalate incidents.

   

Process

Real-time alert review, rule-based monitoring, investigation, account restriction, suspicious transaction escalation

Protects deposit and access services from misuse and feeds incident response, compliance, and customer communication.

   

Technology

Fraud monitoring engine, AML transaction monitoring, SIEM/security monitoring tools, case management

Interfaces with transaction streams from branch, ATM, and digital channels to detect abnormal behaviour.

   

Third Party

External fraud intelligence feeds, card/network partners, telecom providers for OTP and alerts

Improve detection capability and support coordinated response across external ecosystems.

1.14

Exception Handling, Dispute & Error Resolution

People

Compliance officers, regulatory reporting team, finance staff, internal control reviewers

They interpret rules, prepare required submissions, validate accuracy, and monitor compliance breaches.

   

Process

Compliance monitoring, report compilation, exception reporting, breach escalation, and record retention

Converts operational and transaction data into supervisory reporting and assurance outputs.

   

Technology

Regulatory reporting tools, data warehouse, compliance dashboards, and document retention systems

Draws information from onboarding, transactions, fraud, reconciliation, and servicing records.

   

Third Party

External legal/compliance advisory services were used, secure filing/connectivity providers

May support interpretation, submission, and retention of required records.

1.15

Fraud Monitoring & Protective Controls

People

Incident managers, business continuity coordinators, IT DR team, branch leadership, communications team, senior management

They assess disruption, activate response plans, coordinate workarounds, communicate with stakeholders, and restore service.

   

Process

Incident detection, escalation, crisis communication, workaround activation, service recovery, lessons learned

This is the resilience overlay for all prior sub-CBS activities, ensuring CBS-1 can continue or recover within tolerance.

   

Technology

Incident management platform, DR environment, backup systems, communication tools, monitoring dashboards

Supports failover, coordination, recovery tracking, and restoration of branches, ATMs, and digital channels.

   

Third Party

Telecom and power utilities, alternate site providers, managed recovery vendors, critical service partners

Their continuity capability directly affects the bank’s ability to sustain or restore CBS-1 during disruption.

1.19

Dormancy, Restriction, Freeze & Closure Management

People

Branch officers, compliance, legal, and deposit operations

Review and execute dormancy tagging, account restrictions, freezes, closures, and customer advisories.

   

Process

Dormancy control, freeze/restriction workflow, closure processing, residual-balance handling

Interacts with fraud, compliance, customer maintenance, and reporting processes.

   

Technology

Core banking status controls, workflow systems, and case-management tools

Enforces changes to account status and prevents unauthorised transactions.

   

Third Party

Legal/regulatory interfaces, courier/notification vendors where needed

Support required notices, documentation, and external instructions.

1.20

Third-Party & Infrastructure Dependency Management for Deposit Services

People

Vendor managers, procurement, IT infrastructure teams, and operational risk teams

Oversee supplier performance, resilience requirements, and concentration risk.

   

Process

Vendor due diligence, contract management, resilience assessment, exit/substitution planning

Ensures upstream providers can support deposit services during disruption and that fallback options exist.

   

Technology

Network monitoring, service-level dashboards, CMDB, dependency inventory

Tracks which deposit-service components rely on specific vendors, networks, and infrastructure.

   

Third Party

Telecoms, power, cloud/data centre, card/personalisation vendors, payment networks, print/courier providers

Represents the external dependency layer underpinning onboarding, servicing, access, payments, reporting, and recovery.

 
 

Regulatory Requirements from BSP Circular No. 1203 Relevant to This Chapter

Under BSP Circular No. 1203, a Philippine bank must identify its critical operations, set a tolerance for disruption, determine severe but plausible scenarios, and map interconnections and interdependencies to identify vulnerabilities in the delivery chain.

The Circular states that identified critical operations drive subsequent steps, such as tolerance-setting and mapping, and that the mapping should cover the chain of activities and key dependencies that support those operations.

The Circular also gives practical direction relevant to the table above. It expects BSFIs to use operational risk processes to assess threats, control breakdowns, process or system weaknesses, and vulnerabilities affecting critical operations; to consider the effect of change management on interconnections and interdependencies; and, where third parties are involved, to conduct due diligence and avoid arrangements that cannot support the bank’s tolerance for disruption.

It further requires technology and security controls, regular testing, integration with BCM and incident recovery planning, and periodic exercises covering critical operations and their key dependencies using severe but plausible scenarios.

 

Illustrative examples for Chinabank include:
  • a failure of onboarding or KYC utilities that prevents new account opening;
  • disruption of ATM or network connectivity affecting cash withdrawal and balance inquiry services;
  • breakdown in reconciliation after a channel outage, causing posting mismatches;
  • Failure of a statement or notification vendor affecting customer communication;
  • fraud or cyber incidents affecting digital account access and transaction authorisation.

    These examples follow the Circular’s expectation that banks assess dependencies across processes, systems, personnel, and third parties, then test whether critical operations can still be delivered or restored within the bank’s defined tolerance.

 

Banner [Summing] [OR] [E3] Map Dependency

This Map Dependency chapter for CBS-1 Deposit and Account Services shows that Chinabank's operational resilience is not limited to the core banking platform alone.

It depends on the coordinated performance of frontline staff, operations and compliance teams, digital and branch channels, fraud controls, reconciliation routines, communication arrangements, and external providers.

The BCM Institute’s mapping approach is useful here because it forces the bank to see the service end-to-end, including dependencies it does not fully control.

From the perspective of BSP Circular No. 1203, the value of this mapping is that it helps the bank identify weak links, determine where disruption tolerance may be breached, and design more realistic continuity, recovery, and incident response measures.

For Chinabank, the most important practical use of this table is as a working baseline for the next implementation steps: mapping processes and resources in more depth, setting impact tolerances, defining severe but plausible scenarios, and running scenario tests against the dependencies identified for CBS-1.

 

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