[OR] [BSN] [E2] [C12] Performing Scenario Testing

Chapter 12

 Performing Scenario Testing – Stage 4 of the Implement Phase of BSN’s Operational Resilience Planning Methodology

In an increasingly complex and interconnected banking landscape, scenario testing emerges as a cornerstone of BSN’s operational resilience framework.

As part of the “Implement” phase of the Operational Resilience Planning Methodology, scenario testing enables Bank Simpanan Nasional (BSN) to examine how its critical business services perform under adverse, yet realistic conditions.

Unlike traditional continuity testing, scenario testing focuses on understanding the broader impact of disruptions on customer outcomes, regulatory obligations, and reputational standing.

At its core, this phase challenges the assumptions embedded within BSN’s response and recovery strategies. It bridges the gap between documented plans and real-world execution by assessing the practical resilience of business units, technology infrastructure, supply chains, and communication channels.

Scenario testing also fosters cross-functional learning, enhances crisis coordination, and ensures that impact tolerances—such as maximum tolerable downtime and customer harm thresholds—are not only defined but can be adhered to in practice.

For BSN, this proactive approach aligns with Bank Negara Malaysia's resilience requirements and reinforces public confidence in its services, even amidst turbulence.

Objectives of Scenario Testing

• Validate the resilience of critical business services under stress.
• Identify gaps in existing recovery capabilities and response procedures.
• Assess whether the recovery time objectives (RTOs) and impact tolerances are achievable.
• Strengthen cross-departmental coordination and decision-making processes during crises.
• Ensure alignment with regulatory expectations from Bank Negara Malaysia (BNM) and international resilience standards.

Key Implementation Steps

Step 1: Define Test Scope and Objectives

Begin by identifying the Critical Business Services (CBS) and functions to be tested. For BSN, these include:

• CBS-1 Retail Banking Services
• CBS-2 Government Aid and Disbursement Services
• CBS-3 ATM and Self-Service Banking Infrastructure
• CBS-4 Digital Banking (myBSN Online and Mobile Banking App)
• CBS-5 Loan Disbursement and Repayment Processing
• CBS-6 Agent Banking (BSN Banking Agents)
• CBS-7 Treasury and Liquidity Management
• CBS-8 Core Banking System (CBS Infrastructure)
• CBS-9 Customer Complaint and Dispute Resolution
• CBS-10 Regulatory Reporting and Compliance

Example:

For CBS-2 (Government Aid and Disbursement Services), BSN may set a scenario to test how well it can disburse emergency aid to beneficiaries during a national IT outage.

Step 2: Develop Severe but Plausible Scenarios

Construct realistic yet challenging scenarios that reflect BSN’s operational environment, risk landscape, and customer base. These should be considered:

• Cyberattacks targeting digital banking channels
• Widespread ATM network failure
• Regional data centre outage due to power grid collapse
• Third-party service provider disruption
• Simultaneous pandemic and social unrest

Example:

A coordinated cyberattack brings down both myBSN and ATM services across multiple regions. BSN tests how quickly it can reroute transactions through agent banking and restore digital services.

Step 3: Design the Scenario Exercise Format

Choose the appropriate format for the test:

• Tabletop Exercise (discussion-based simulation)
• Live Simulation/Walkthrough
• Technical Failover Testing
• Cross-functional Crisis Simulation

Example:

BSN conducts a tabletop exercise involving Digital Banking, IT, Customer Service, and Corporate Communications to simulate a ransomware attack affecting CBS-4.

Step 4: Identify Stakeholders and Roles

Ensure involvement from all relevant teams:

• Business Units: Retail, Loans, and Branch Operations
• IT and Cybersecurity
• Crisis Management and Risk Management
• Regulatory Liaison and Compliance
• Corporate Communications
• Vendors/Third-Party Providers (if applicable)

Example:

During a test of CBS-5 (Loan Disbursement), BSN involves system vendors and BNM liaison officers to assess response coordination.

Step 5: Execute the Test

Simulate the selected scenario under controlled conditions. Monitor actions taken, decisions made, and time taken to respond and recover.

Key elements to document include:

• Time to detect the incident
• Activation of crisis response
• Communication flow and escalation
• Recovery of impacted services
• Customer notification processes

Step 6: Observe, Record, and Evaluate

Assign observers to each functional area. Record actual vs. expected response times and note deviations from plans.

Example:

BSN finds that during the ATM disruption test, customer communication was delayed by 45 minutes due to unclear escalation protocols.

Step 7: Conduct Post-Test Debriefing

Hold a structured after-action review with all participants. Identify:

• What went well
• What did not work as intended
• Gaps in procedures, tools, or knowledge
• Immediate corrective actions are required

Step 8: Document Lessons Learned and Update Plans

Incorporate improvements into Business Continuity Plans (BCPs), IT Disaster Recovery Plans (IT DRPs), and Operational Resilience Playbooks.

Example

After testing a myBSN outage, BSN revises its communication SOP to include SMS alerts to customers when the mobile app is down for more than 15 minutes.

Step 9: Report to Management and Regulators

Summarise the outcomes of each test and report to senior management and, where applicable, to BNM. Include:

• Objectives vs. results
• Identified gaps
• Action plans with owners and deadlines
• Updated risk posture and control effectiveness

Table 12-1: Summary of Scenario Testing

Summing Up ...

Scenario testing is more than a compliance requirement—it is a vital diagnostic tool that reveals the true strength and flexibility of Bank Simpanan Nasional's operational resilience framework.

Through the deliberate application of stress on critical business services, BSN can simulate high-impact events, observe real-time reactions, and validate the robustness of its response capabilities.

Each exercise, regardless of outcome, contributes to a feedback loop that strengthens procedures, enhances staff competencies, and fortifies BSN’s promise to remain reliable, even under stress.

As BSN continues to innovate and expand its service delivery channels—especially in digital and rural agent-based banking—scenario testing must evolve accordingly.

Periodic exercises, incorporating new threat vectors and stakeholder complexities, will ensure that BSN's resilience posture remains aligned with national expectations, international standards, and the expectations of millions of Malaysians who rely on it.

Ultimately, scenario testing is the proving ground for trust—and it is this trust that anchors BSN’s mission in both crisis and continuity.

 

	Operational Resilience for Financial Services: The BSN Malaysia Approach
	"Implement" Phase of the Operational Resilience Planning Methodology

 

 

OR Planning Methodology Phases		Plan	Implement	Sustain

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