In a Changing World, Questions For the CRO

Before the financial crisis in 2008-2009, many businesses didn’t think of risk as something to be proactively managed. After the crisis, however, that paradigm shifted. Companies began perceiving risk management as a way to protect both their reputations and their stakeholders.

Today, risk management is not just recommended, it is considered crucial to successful operations and is required by federal and state law. The SEC’s Proxy Disclosure Enhancements, enacted in 2010, mandate that organizations provide information regarding board leadership structure and the company’s risk management practices. Company leadership is required to have a direct role in risk oversight, and any risk management ineffectiveness must be disclosed.

The CRO’s role

Volatility in the current business environment—a confluence of factors including transfers of power, the world economy and individual markets—is nothing new. Political transitions have always been accompanied by new agendas and shifting regulations, economies have always experienced bull and bear markets, and the evolution of technology constantly changes our processes.

Even so, recent events like Brexit, the uncertainty of a new administration’s regulatory initiatives, and thousands of annual data breaches have contributed to an unprecedented atmosphere of fear and doubt. To navigate this environment, the chief risk officer needs to adopt a proactive risk management approach. Enterprise-wide risk assessments grant the visibility and insight needed to present an accurate picture of the company’s greatest risks. This visibility is what the board needs to safely recognize opportunity for innovation and expansion into new markets.

To grow a business safely—by innovating and adding to products/services and expanding into new markets—risk professionals should not focus on identifying risk by individual country. This approach naturally leads to a prioritization of “large-dollar” countries, which aren’t necessarily correlated with greater risk. Countries that contribute a small percentage of overall revenue can still cause major, systemic risk management failures and scandals.

A better approach is to look at risk across certain regions; how might expanding the business into Europe, for example, create new challenges for senior management? Are there sufficient controls in place to mitigate the risks that have been identified?

When regional risks are aggregated to create a holistic picture, it becomes possible for the board to make sure expansion efforts are aligned with strategic goals.

Three processes that require ERM

Risk management is an objective process, and best practices, such as pushing risk assessments down to front-line process owners who are closest to operational risk, should be adhered to regardless of the current state of the international business arena.

While today’s political climate has generated a significant amount of media strife, it’s important not to let emotion influence decision-making. By providing the host organization with a standardized framework and centralized data location, enterprise risk management enables managers to apply the same basic approach across departments and levels.

This is particularly important when an organization expands internationally, which involves compliance with new sets of regulations and staying competitive. Performing due diligence on an ad hoc basis is neither effective nor sustainable. Instead, the process should follow the same best-practice process as domestic risk management efforts:

  1. Identify and assess. Make risk assessments a standard part of every budget, project or initiative. This involves front-line risk assessments from subject matter experts, revealing key risks and processes/departments likely to be affected by those risks. For example, financial scrutiny is no longer a concern just for banks. Increased attempts to fight terrorism mean transactions of all kinds are becoming subject to more review. Anti-bribery and anti-corruption processes estimate and quantify both vulnerability and liability.
  2. Mitigate key risks. Connect mitigation activities to the resources they depend on and the processes they’re associated with. ERM creates transparency into this information, eliminating inefficiency associated with updating/tracking risks managed by another department. Control evaluation is the most expensive part of operations. Use risk management to prioritize this work and reduce expenses and liability.
  3. Monitor the effectiveness of controls with tests, metrics, and incident collection for risks and controls alike. This ensures performance standards are maintained as operations and the business environment evolve. Evidence of an effective control environment prevents penalties and lawsuits for negligence. The bar for negligence is getting lower; technology is pulling the curtain back not only internally but (through social media and news) to the public as well.

Lastly, the CRO role is increasingly accountable for failures in managing risk along with other senior leaders and boards—look no further than Wells Fargo.

Increasing Risk Complexity Outpaces ERM Oversight

More organizations are recognizing the value of a structured focus on emerging risks. The number of organizations with a complete enterprise risk management (ERM) program in place has steadily risen from 9% in 2009 to 28% in 2016, according to the N.C. State Poole College of Management’s survey “The State of Risk Oversight: An Overview of Enterprise Risk Management Practices.”

Yet this progress may lag behind the increasingly complicated risks that need addressing. Of respondents, 20% noted an “extensive” increase in the volume and complexity of risks the past five years, with an additional 38% saying the volume and complexity of risks have increased “mostly.” This is similar to participant responses in the most recent prior years. In fact, only 2% said the volume and complexity of risks have not changed at all.

Even with improvements in the number of programs implemented, the study—which is based on responses of 432 executives from a variety of industries—found there is room for improvement. Overall, 26% of respondents have no formal enterprise-wide approach to risk oversight and currently have no plans to consider this form of risk oversight.

Organizations that do have programs continue to struggle to integrate their risk oversight efforts with strategic planning processes. “Significant opportunities remain for organizations to continue to strengthen their approaches to identifying and assessing key risks facing the entity especially as it relates to coordinating these efforts with strategic planning activities,” the researchers found.

According to the study:

Many argue that the volume and complexity of risks faced by organizations today continue to evolve at a rapid pace, creating huge challenges for management and boards in their oversight of the most important risks. Recent events such as Brexit, the U.S. presidential election, immigration challenges, the constant threat of terrorism, and cyber threats, among numerous other issues, represent examples of challenges management and boards face in navigating an organization’s risk landscape.

Key findings include:

Eliminating Language Barriers Between Information Security and the C-Suite

Whether or not security operations pose a core focus to a company or are an afterthought, the largest obstacle now affecting business and security outcomes is the language barrier that exists between security teams and the C-Suite.

In general, security groups’ budgets have increased over the years, with organizations adding more vendors to the mix, “layering” security with the latest new tool to address the latest threat. One of the newest such tools is “threat intelligence” which organizations are using to form an “intelligence-led security” program, a security operations center, or incident response capabilities. While threat intelligence and other solutions hold the answers to many of the important questions executives ask about cyberattacks, this terminology means nothing to C-level executives, nor does the output from these systems and programs. What does it mean that you have stopped one billion attacks this past month? What impact have the 30 incident responses you’ve run over that same period of time had on the business? What’s the significance to reducing response time from one month to one day?

Executives running and overseeing a company have two primary concerns: increasing revenue and shareholder value. There is a big disconnect between security and the C-suite because they speak two different languages. One is a very technical language that needs a translation layer to explain it to the executives. The other is a very strategic language that needs to be conveyed in a way that makes security part of the team and company, and ensures alignment and participation with the business units and executive suite.

What’s the fix? Communication. Each group has to understand the other at least enough to relay the core concepts as they apply to the other and in a language the other understands. As a first step, some companies are adding a technical expert—a “designated geek,” if you will—to their board of directors so they can work on improving communication and understanding. While that can help, it takes a lot more to make sure priorities, efforts and results don’t get lost in translation.

A Two-Way Street

Executives need to include the chief information security officer or chief technical officer as part of their strategic discussions and make sure that security leadership has the ability to push that communication down to their teams in a way everyone understands. To that end, CISOs and executives need to train their security operations personnel to ensure they understand the business. This starts by asking some critical questions:

  • Does every member of the security team understand what is it that you sell/produce/provide?
  • What are the things your security teams need to watch out for to protect revenue?
  • Many organizations operate large industrial control systems. If your organization has such a system, is your security team aware of this?
  • If your company is moving into the cloud or is about to launch a mobile app, does your security team know about this and have you enabled them to get the right monitoring in place to protect it?
  • Have you involved the security team as you were designing that new revenue stream, or evolving your business model in some other way, to be sure that security isn’t an afterthought?

These are just a few examples of how executives need to think about the enterprise to ensure that security is strategically aligned. It is incumbent on the business to train the security personnel on its priorities so that security teams can look for attacks that are important to the business and take action.

Likewise, security teams need to change how they communicate to the C-suite. Every security team should conduct a stakeholder analysis to identify who needs to be informed of what and when. It all comes down to content, format and frequency. Make sure you have regular communications with not only your peers in security and network operations, but with the business units, risk management, C-level executives, the board of directors, and anyone else in the company that is involved in the day-to-day objectives and operations of the company. The CISO should be the link to make this connection happen, working with executives to establish regular communication.

There is no “right way” to communicate. Some executives and boards are more technical than others. Security teams need to take the time to learn what type of communication will be most effective or forever struggle to align security with the business. Sticking with the generated metrics of number of events, alerts and incidents per month has far less impact than an update that contains the “who, what, when, where and why” of a thwarted attack. For example: “We identified and stopped one attack this month from a cyber espionage group targeting our Western European manufacturing facility, which is responsible for $20 million per year in revenue to the company.”

For those in security who feel they can’t deliver such a statement because their security infrastructure doesn’t provide that kind of information about threat actors and campaigns, there is a path forward. Look into creating a program that uses adversary-focused, contextual cyber threat intelligence and make sure you understand enough about your business to know the impact of threats against the various business units. With the communication gap closed, and security and business goals aligned, organizations can become more secure, and profitable.

Can ORSA Work For All Businesses?

In addition to impacting the way countless organizations conduct business, the 2008 financial crisis was an awakening for regulators charged with reviewing and setting the rules that shape the way organizations assume risk. Insurance, perhaps the riskiest business of them all, did not go unscathed.

Not only are insurers responsible for managing their own internal risks, but careful calculations and guidelines are built into their business models to ensure that the risks fall within set parameters. Regulators will argue, however, that this wasn’t always the case.

Own Risk Solvency Assessment (ORSA) was adopted and now serves as an internal process for insurers to assess their risk management processes and make sure that, under severe scenarios, they remains solvent.

U.S. insurers required to perform an ORSA must file a confidential summary report with their lead state’s department of insurance.  The assessment aims to demonstrate and document the insurer’s ability to:

  • Withstand financial and economic stress with a quantitative and qualitative assessment of exposures
  • Effectively apply enterprise risk management (ERM) to support decisions
  • Provide insights and assurance to external stakeholders

While ORSA is requirement for insurers, a new study by RIMS and the Property Casualty Insurers Association, Communicating the Value of Enterprise Risk Management: The Benefits of Developing an Own Risk and Solvency Assessment Report, maintains that ORSA can be used for all organizations looking to strengthen their ERM function.

According to the report:

Whether or not required by regulation or standard-setting bodies, documenting the following internal practices is a worthwhile endeavor for any company in any sector to utilize in their goal to preserve and create value:

  • Enterprise risk management capabilities

  • A solid understanding of the risks that can occur at catastrophic levels related to the chosen strategy

  • Validation that the entity has adequately considered such risks and has plans in place to address those risks and remain viable.

The connection between the ORSA regulation imposed on insurers and the development of an ERM program within an organization outside of the insurance industry is apparent.

ORSA and ERM both require the organization to strengthen communication between business functions. Breaking down those silos are key to uncovering business risk, but perhaps more importantly, is the interconnectedness of those risks.

Secondly, similar to ERM in non-insurance companies, ORSA requires risk management to document its findings, processes and strategies. Such documentation allows for the process of managing risks to be effectively communicated to operations, senior leadership, regulators and stakeholders. Additionally, documentation enhances monitoring efforts, the ability to make changes to the program and is a benefit that allows ERM to reach a “repeatable” maturity level as defined by the RIMS Risk Maturity Model.

Developing an ERM program has become a priority for many organizations as senior leaders recognize the value of having their entire organization thinking, talking and incorporating risk management into their work. Examining and implementing ORSA strategies can be an effective way for risk professionals to get their ERM program off the ground and operational.