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Well worth a weekend read, if you are a Financial Institution that trades in the UK and trades in the EU. As the The Bank of England fines Vocalink £11.9 million of failure in governance and risk management. Rolf von Roessing you are correct in your comments, the size of the fine is incidental. When one reads the enclosed final notice, it makes clear that here were failings across the company by the board room, by approved persons and from the shop floor. Worst, the failings related to previous oversight by the BoE and expected remediation, that did not take place.
The challenge for Vocalink, a Mastercard company is not just UK compliance, its how the company responds to its customers in the EU. Customers that are required to comply to the Digital Operational Resilience Act (DORA), that includes their suppliers (Vocalink). One suspects that the European Central Bank, EU State Central Banks and finance regulators will pay attention to the enclosed notice. Where one regulator has travelled, others regulators will follow.
The enclosed notice makes for an intense read. Demonstrating failures across the 3 lines of defense; basic failures of governance and remediation; failures of oversight committees, and management.
The notice is a useful read when one considers DORA compliance. The notice highlights failings that are addressed by DORA. That UK firms are impacted by, along with EU NIS 2, if they trade in or with the EU. One will be contributing to a DORA education program next week with Ryan Buckner of Schellman, with a new case study.
@Thaddeus Dziekanowski Brian D. McCarthy Faisal Khan Bryan Foss
Veritas GRC
#dora #ictrisk #cyberriskmanagement #regulatorycompliance
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