Rather than testing isolated systems or departments, scenario testing evaluates the end-to-end impact on service, spanning people, processes, technology, third-party dependencies, and data.
This approach is consistent with regulatory expectations outlined in the 2025 BNM Discussion Paper on Operational Resilience, which emphasises forward-looking preparedness, ICT and cyber resilience, and management’s ability to respond decisively under stress.
For CBS-1, scenario testing focuses on disruptions that could impair market access, trade execution, settlement integrity, and regulatory reporting—areas where operational failure could result in significant financial loss, regulatory breaches, and reputational damage.
The following table outlines recommended scenario-testing themes for each Sub-CBS, explicitly integrating Cyber and ICT risk scenarios and highlighting evidence of proactive risk-management actions expected of a resilient investment bank.
|
Sub-CBS Code |
Sub-CBS |
Recommended Scenario Test Themes |
Impact / Effect |
Evidence of Proactive Risk Management Action |
|
1.1 |
Client Onboarding & Order Intake |
Cyber attack on client onboarding platform; identity data compromise; CRM system outage |
Inability to onboard new clients or accept orders; data confidentiality breach |
Regular cyber penetration testing; dual onboarding channels; data encryption and access reviews |
|
1.2 |
Order Validation & Pre-Trade Checks |
Corrupted market reference data; rules engine failure due to ICT outage |
Invalid or non-compliant orders processed; regulatory exposure |
Automated validation controls; manual override procedures tested; periodic rule-set integrity checks |
|
1.3 |
Order Routing & Trade Execution |
Exchange connectivity failure; DDoS attack on the order routing gateway |
Trades fail to reach the market; missed execution opportunities |
Multi-exchange connectivity; alternate routing paths; cyber DDoS mitigation drills |
|
1.4 |
Trade Capture & Enrichment |
Trade capture system outage; interface failure between front and middle office |
Incomplete or inaccurate trade records |
Near-real-time trade replication; fallback capture tools; reconciliation rehearsals |
|
1.5 |
Trade Validation & Verification |
Data integrity failure due to malware; middle-office system degradation |
Undetected trade errors; downstream settlement issues |
Segregation of duties; automated exception alerts; ICT resilience testing |
|
1.6 |
Trade Confirmation & Affirmation |
Secure messaging platform outage (e.g., SWIFT or equivalent); cyber spoofing attempt |
Delayed or disputed confirmations |
Alternate confirmation channels; message authentication controls; cyber fraud simulations |
|
1.7 |
Trade Settlement Instruction & Clearing |
Clearing system unavailability; ransomware attack on settlement systems |
Settlement failure; liquidity and counterparty risk |
Offline settlement procedures; immutable backups; coordination tests with clearing houses |
|
1.8 |
Post-Trade Reconciliation & Exception Handling |
Reconciliation tool failure; data mismatch from ICT integration error |
Unresolved breaks; operational backlog |
Daily reconciliation thresholds; surge staffing plans; system recovery time testing |
|
1.9 |
Trade Reporting & Regulatory Compliance |
Regulatory reporting platform outage close to submission deadline; data loss incident |
Late or inaccurate regulatory submissions; supervisory findings |
Pre-submission data validation; manual reporting templates; ICT recovery drills aligned to reporting timelines |
|
1.10 |
Client Settlement & Confirmation Delivery |
Client portal outage; email system compromise; data leakage incident |
Clients do not receive settlement advice; trust erosion |
Multi-channel delivery (portal/email/SFTP); cyber awareness drills; client communication playbooks |
Scenario testing for CBS-1 Securities Broking & Trade Execution enables Kenanga Investment Bank to move beyond compliance-driven continuity planning toward demonstrable operational resilience.
By designing scenarios that reflect realistic market stress, ICT failures, cyber threats, and third-party disruptions, management gains clarity on whether important business services can remain within defined impact tolerances—even under extreme conditions.
Consistent with the BNM 2025 Operational Resilience Discussion Paper, the emphasis is not on preventing disruption entirely, but on anticipating failure, limiting harm, and recovering in an orderly manner.
The evidence of proactive risk management—such as tested fallback arrangements, cyber-resilience measures, and cross-functional response playbooks—provides regulators, clients, and stakeholders with confidence that Kenanga Investment Bank can continue to execute securities trades safely, fairly, and reliably in times of stress.
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Resilience by Design: Kenanga Investment Bank’s Operational Resilience Journey |
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| eBook 3: Starting Your OR Implementation |
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| CBS-1 Securities Broking & Trade Execution | |||||
| CBS-1 DP | CBS-1 MD | CBS-1 MPR | CBS-1 ITo | CBS-1 SuPS | CBS-1 ST |
To learn more about the course and schedule, click the buttons below for the OR-300 Operational Resilience Implementer course and the OR-5000 Operational Resilience Expert Implementer course.
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If you have any questions, click to contact us. |
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