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Since 2015, integrity risk analysis has been one of the priorities in the cross-sector supervision performed by De Nederlandsche Bank (DNB). Banks, insurers, pension funds and trust offices are obligated to carry out a systematic integrity risk analysis (SIRA). A SIRA covers a wide range of integrity risks. For example, money laundering, bribery and corruption, funding of terrorism and privacy and data-related breaches.
‘How can your financial institution perform a systematic integrity risk analysis, which is one of the supervision priorities of DNB?’
Financial institutions must identify, analyse, manage and periodically monitor integrity risks. This involves institutions assessing the gross as well as the net risk – the risks before and after taking measures – and taking (improvement) measures to mitigate risks that are not part of their risk appetite.
Besides modifying your SIRA, due to changes in your organisation, a whole range of operational optimisations are normally possible. For instance, is the SIRA sufficiently embedded in your organisation? How compatible is your SIRA with your control framework? And can your institution use data analysis to make the SIRA even smarter?
DNB provides the risk based approach but leaves it to the financial institutions to determine which tax integrity risks are within their tax risk appetite and therefore acceptable. This is complex: not only relevant (inter)national tax regulations, but also stakeholder views and the (sustainable) business strategy of the financial institution have to be taken into account.
Based on the guidance of DNB, and our experience at a variety of clients, we have developed an approach for setting up the SIRA. Our high-level approach is as follows:
We possess the extensive expertise needed to assist you with all SIRA-related activities, irrespective of the size or maturity of your organisation. The support we offer includes:
· Setting up a SIRA process
· Optimising your existing SIRA process
· Advanced risk assessment based on data analysis
· Advice about specific aspects of integrity risk, like tax evasion and fiscal fraud
· Coordination of SIRA with your control framework and evaluation of its effectiveness
Our specialists have considerable experience with fully implementing SIRA for clients that request DNB licences. We can also help to set up or optimise individual components: