[OR] [MBT] [E3] [CBS] [11] [SuPS] Identify Severe but Plausible Scenarios

Written by Moh Heng Goh | Dec 3, 2025 6:21:57 AM

CBS-11 Overseas Remittance and Foreign Exchange Services

In the ever-evolving landscape of operational resilience, identifying severe yet plausible scenarios is crucial to ensure the stability and compliance of critical business services.

For Metrobank's CBS-11 Regulatory and Compliance Reporting, these scenarios reflect potential disruptions that could significantly impact the organisation’s ability to meet regulatory requirements, impacting both operational continuity and compliance posture.

Here’s the table format for the "Severe but Plausible Scenarios" for each process within CBS-11 Regulatory and Compliance Reporting:

Table P5: Identify Severe but Plausible Scenarios for CBS-11

Sub-CBS Code	Sub-CBS	Severe but Plausible Scenario	Impact/Effect	Proactive Risk Management Action
11.1	Regulatory Reporting Framework	Cyberattack targeting reporting systems	Loss of regulatory reporting capability; potential non-compliance and penalties.	Regular updates and patching of reporting systems; robust cybersecurity measures; staff training on data security.
11.2	Compliance Monitoring and Auditing	Inability to access regulatory data due to a system failure	Failure to monitor compliance effectively, reputational damage, and fines.	Implementation of redundant systems; cloud backups for regulatory data; continuous monitoring of compliance status.
11.3	Submission of Regulatory Reports	Misreporting due to human error or system malfunction	Legal consequences, potential regulatory fines, and operational delays.	Automating report generation with validation checks, regular staff training, and clear guidelines.
11.4	Risk Assessment and Mitigation in Reporting	Data corruption or loss during risk assessment	Inaccurate risk reports lead to poor mitigation strategies and compliance issues.	Implementing integrity checks and encryption for data, and frequent data backups.
11.5	Reporting Systems and Technology	System downtime due to a DDoS attack or software failure	Interruptions in the reporting process; inability to meet regulatory deadlines.	Development of a disaster recovery plan and system failover capabilities; regular testing of business continuity protocols.

Identifying severe but plausible scenarios for CBS-11 Regulatory and Compliance Reporting helps establish the groundwork for robust risk management strategies.

By considering these potential disruptions and proactively implementing risk mitigation actions, Metrobank can enhance its operational resilience, safeguard regulatory compliance, and reduce the potential for severe impacts.

Building Resilient Banking Operations: The Metrobank Operational Resilience Implementation Guide
eBook 3: Starting Your OR Implementation
CBS-11 Regulatory and Compliance Reporting
CBS-11 DP	CBS-11 MD	CBS-11 MPR	CBS-11 ITo	CBS-11 SuPS	CBS-11 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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