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Ensuring Service Continuity and Compliance: ISO 22301 BCMS at Bank of Maldives
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[BCM] [BML] [E3] [BIA] [T3] [CBF] [1] Retail & Corporate Banking Services

Banner [BCM] [E3] [BIA] [P5] Inter-dependencies

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Understanding inter-dependencies is a critical requirement under ISO 22301, as the continuity and recoverability of any critical business function is directly influenced by its reliance on other internal functions, external service providers, vendors, and stakeholders.

For CBF-1 Retail & Corporate Banking Services, these inter-dependencies span across technology platforms, payment infrastructures, regulatory bodies, outsourced service providers, and customer-facing delivery channels.

This section identifies and documents the internal and external dependencies associated with each Sub-CBF, including whether the dependency is upstream, downstream, or mutual.

Banner [BCM] [E3] [BIA] [P6] Vital Records

Vital records are records that are essential for the Bank of Maldives to continue its critical operations during and after a disruptive incident, as well as to meet legal, regulatory, financial, and contractual obligations.

In accordance with ISO 22301 and leading BCM practices, the identification, protection, accessibility, and recovery of vital records are a foundational component of effective Business Continuity Management.

For CBF-1 Retail & Corporate Banking Services, vital records support customer trust, transaction integrity, regulatory compliance, and financial stability. These records must remain available within defined recovery time objectives (RTOs), be protected against loss or corruption, and be clearly assigned to accountable custodians.

Dr Goh Moh Heng
Business Continuity Management Certified Planner-Specialist-Expert
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Banner [BCM] [E3] [BIA] [P5] Inter-dependencies

CBF-1 Retail & Corporate Banking Services 

[BCM] [BML] [E3] [BIA] [T3] [CBF] [1] Retail & Corporate Banking ServicesUnderstanding inter-dependencies is a critical requirement under ISO 22301, as the continuity and recoverability of any critical business function is directly influenced by its reliance on other internal functions, external service providers, vendors, and stakeholders.

For CBF-1 Retail & Corporate Banking Services, these inter-dependencies span across technology platforms, payment infrastructures, regulatory bodies, outsourced service providers, and customer-facing delivery channels.

This section identifies and documents the internal and external dependencies associated with each Sub-CBF, including whether the dependency is upstream, downstream, or mutual.

This analysis enables Bank of Maldives to assess potential cascading failures, prioritise recovery strategies, and design robust continuity and resilience measures in line with ISO 22301 requirements.

Banner [Table] [BCM] [E3] [BIA] [P5] Inter-dependencies  [BIAQ]

Table P5: Inter‑dependencies for CBF-1

Sub-CBF Code

Sub-CBF

Name of Business Unit or Vendor / Supplier / Outsource Partner

Type of Dependency – Internal

Type of Dependency – External

Dependency Direction (Upstream / Downstream / Mutual)

Description of Nature of Dependency

1.1

Customer Onboarding & Account Opening

Compliance & KYC Unit

 

Upstream

Customer due diligence, AML screening, and identity verification must be completed before account activation.

1.1

Customer Onboarding & Account Opening

National ID Authority / Credit Bureau

 

Upstream

External verification of customer identity and credit history is required to meet regulatory obligations.

1.2

Deposit & Withdrawal Services

Branch Operations

 

Mutual

Branch staff and cash operations support deposit and withdrawal transactions while relying on system availability.

1.2

Deposit & Withdrawal Services

Core Banking System Vendor

 

Upstream

Real-time transaction processing depends on the availability of the core banking platform.

1.3

Payment Processing & Fund Transfers

Payments & Clearing Department

 

Mutual

Internal processing, reconciliation, and exception handling are required for successful fund transfers.

1.3

Payment Processing & Fund Transfers

Maldives Monetary Authority (RTGS / Clearing)

 

Upstream

Interbank payments rely on central bank settlement and clearing infrastructure.

1.4

Lending & Credit Management

Credit Risk Management Unit

 

Upstream

Credit approval, risk assessment, and policy validation are prerequisites for loan disbursement.

1.4

Lending & Credit Management

Credit Bureau / Valuation Firms

 

Upstream

External credit reports and asset valuations support lending decisions and risk mitigation.

1.5

Card Services & Merchant Solutions

Card Operations Unit

 

Mutual

Card issuance, dispute handling, and merchant support require operational coordination.

1.5

Card Services & Merchant Solutions

Visa / Mastercard / Payment Networks

 

Upstream

Transaction authorisation and settlement depend on international card network availability.

1.6

Digital & Online Banking

IT & Digital Banking Department

 

Mutual

Application support, cybersecurity monitoring, and system maintenance are critical for service availability.

1.6

Digital & Online Banking

Telecom & Internet Service Providers

 

Upstream

Network connectivity is required for customer access to digital banking platforms.

1.7

Trade & Corporate Financial Solutions

Trade Finance Operations

 

Mutual

Processing of letters of credit, guarantees, and trade documentation relies on operational expertise.

1.7

Trade & Corporate Financial Solutions

Correspondent Banks

 

Mutual

Cross-border trade settlements and confirmations depend on correspondent banking relationships.

1.8

Account Maintenance & Reporting

Finance & Reconciliation Unit

 

Downstream

Accurate reporting and reconciliation rely on transaction data generated by retail and corporate services.

1.8

Account Maintenance & Reporting

Regulatory Authorities (MMA)

 

Downstream

Regulatory reporting obligations depend on timely and accurate account and transaction data.

 

Banner [BCM] [E3] [BIA] [Summing Up] [P5] Inter-dependencies  [BIAQ]

The inter-dependency analysis for CBF-1 Retail & Corporate Banking Services highlights the complex web of internal and external relationships that underpin the Bank of Maldives’ ability to deliver uninterrupted banking services.

Failures in upstream dependencies—such as core banking systems, payment networks, or regulatory infrastructure—can have immediate and widespread downstream impacts on customer services and financial stability.

In accordance with ISO 22301, documenting and understanding these inter-dependencies enables the Bank of Maldives to:

  • Identify single points of failure and concentration risks
  • Establish appropriate recovery priorities and time objectives
  • Strengthen supplier, vendor, and outsourcing resilience
  • Enhance overall operational resilience and continuity capability

This structured dependency mapping forms a critical input into Business Impact Analysis (BIA), continuity strategies, and crisis response planning, ensuring that Retail and Corporate Banking Services remain resilient in the face of disruptions.

 


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Part 6_ Vital Records

Banner [BCM] [E3] [BIA] [P6] Vital Records

CBF-1 Retail & Corporate Banking Services

[BCM] [BML] [E3] [BIA] [T3] [CBF] [1] Retail & Corporate Banking ServicesVital records are records that are essential for the Bank of Maldives to continue its critical operations during and after a disruptive incident, as well as to meet legal, regulatory, financial, and contractual obligations.

In accordance with ISO 22301 and leading BCM practices, the identification, protection, accessibility, and recovery of vital records are a foundational component of effective Business Continuity Management.

For CBF-1 Retail & Corporate Banking Services, vital records support customer trust, transaction integrity, regulatory compliance, and financial stability. These records must remain available within defined recovery time objectives (RTOs), be protected against loss or corruption, and be clearly assigned to accountable custodians.

This section identifies the vital records associated with each Sub-CBF, considering media type, storage location, and ownership, in line with ISO 22301 requirements and the principles outlined in BCM Part 6: Vital Records.

Banner [Table] [BCM] [E3] [BIA] [P6] Vital Records [BIAQ]

Table P6: Vital Records for CBF-1 

Sub-CBF Code

Sub-CBF

Description of Vital Records

Media Type

Location

In Whose Care

1.1

Customer Onboarding & Account Opening

Customer identification documents (KYC), account opening forms, AML screening results, customer agreements, risk profiles

Electronic (Core Banking System, Document Management System), Limited Physical

Primary Data Centre, DR Site; Physical files at Branches

Retail Banking Operations, Compliance Department

1.2

Deposit & Withdrawal Services

Transaction journals, teller logs, cash balance records, account balances, and audit trails

Electronic; Limited Physical (cash vouchers)

Core Banking System at Data Centre and DR Site; Branch vaults

Branch Operations, Operations & Finance

1.3

Payment Processing & Fund Transfers

Payment instructions, transaction confirmations, settlement records, reconciliation reports, SWIFT/MaNET logs

Electronic

Payment Systems, Core Banking System, DR Site

Payments & Clearing Operations

1.4

Lending & Credit Management

Loan agreements, credit approvals, collateral records, repayment schedules, and credit risk assessments

Electronic; Physical (legal documents)

Loan Management System, DMS, Secure Physical Storage

Credit Department, Risk Management

1.5

Card Services & Merchant Solutions

Cardholder data (masked), merchant agreements, transaction logs, chargeback records, settlement files

Electronic

Card Management System, Payment Switch, DR Site

Card Services Unit

1.6

Digital & Online Banking

User authentication logs, transaction records, system audit logs, and customer service requests

Electronic

Digital Banking Platforms, SIEM, DR Site

Digital Banking & IT Operations

1.7

Trade & Corporate Financial Solutions

Letters of credit, guarantees, trade finance contracts, corporate agreements, settlement records

Electronic; Physical (trade instruments)

Trade Finance System, DMS, Secure Records Room

Corporate Banking & Trade Finance

1.8

Account Maintenance & Reporting

Account change requests, customer instructions, regulatory reports, statements, audit, and compliance reports

Electronic

Core Banking System, Reporting Systems, DR Site

Operations, Compliance, Finance

 

Banner [BCM] [E3] [BIA] [Summing Up] [P6] Vital Records [BIAQ]

The effective management of vital records for CBF-1 Retail & Corporate Banking Services is critical to ensuring the Bank of Maldives’ operational resilience, regulatory compliance, and customer confidence during disruptions.

By clearly identifying vital records, their formats, storage locations, and accountable custodians, BML strengthens its ability to respond to incidents, meet recovery objectives, and support timely decision-making under adverse conditions.

In alignment with ISO 22301, these vital records must be subject to ongoing protection measures, regular backups, access controls, and periodic reviews to ensure accuracy and availability.

Integrating vital records management into business continuity and disaster recovery planning enables Bank of Maldives to sustain essential banking services, safeguard stakeholder interests, and reinforce its commitment to resilience and service continuity across the Maldives.

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