Category Archives: Enterprise Risk Management

Flint Water Investigation Leads to Felony Charges for Mich. State Employees

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A driving effort to save the state money was said to be the reasoning behind the Flint, Michigan water crisis, which has been tied to lead poisoning in children, among other issues. On Tuesday the state announced felony charges against former state emergency managers, Darnell Earley and Gerald Ambrose, accused of false pretenses and conspiracy to commit false pretenses. The two were said to have been focused on balance sheets rather than the welfare of citizens when they made the decision in 2014 to switch the city’s water supply from treated water in Lake Huron to water from the Flint River.

A state investigation, which began in January, had led to charges against eight state officials and an employee of the Flint water facility.

According to the New York Times:

Charges of false pretenses, conspiracy to commit false pretenses, misconduct in office and willful neglect of duty lodged against the former managers were lauded by Flint leaders, some of whom said they had feared that blame for the city’s contaminated water might ultimately be pinned only on low-level workers.

The claims also reopened a longstanding debate in Michigan over the state’s emergency management provision, reviving questions about whether the system removes power and control over local issues from those residents who come under state oversight.

For years, governors here have appointed emergency managers as a way to efficiently cut debts and restore financial stability in the most troubled cities. But residents of some majority-black Michigan cities, including Flint, argue that the intense state-assigned oversight disenfranchises voters, shifts control from mostly Democratic cities to the state’s Republican-held capital and risks favoring financial discipline over public health.

After the decision was made to use water from the Flint River, Flint residents had began to notice a peculiar odor, color and taste in the water that flowed from their taps. Some reported skin rashes, hair loss and other physical problems. But they did not know why. Water from the Flint River was used by Flint residents for 18 months, but because it was not treated to reduce corrosion, lead from old plumbing leached into the water. Testing revealed dangerous levels of lead.

Residents soon discovered they had been lied to. Public officials had known about the lead but kept quiet. As a result, between 6,000 and 12,000 children were exposed to the contaminated water, which will likely have serious consequences for their health.

Meanwhile, efforts to fix the problem are underway. State officials switched back to the original water source in October. Michigan Gov. Rick Snyder has estimated that replacing the more than 15,000 lead service lines in Flint would take $60 million and up to 15 years.

Key Steps to a Robust Risk Management Program

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Our business environment is constantly changing—technologies improve, regulations are modified, competition increases, and demand evolves. Effective risk management grants an ability to adapt to these changes.

Recent headline events, including the Volkswagen emissions deception, the Wells Fargo scandal, and the penalty paid by Dwolla to the Consumer Financial Protection Bureau (CFPB), illuminate powerful motivators for strong risk management programs. Key to a robust program is preventing stressful, and possibly catastrophic, surprises.

When Plains All American Pipeline failed to detect corrosion in its pipeline, for example, the result was a 3,000-barrel oil spill and millions of dollars in fines. The corrosion had run under the radar because the company did not delegate sufficient inspection resources and did not maintain proper procedures and systems for preventing problems from escalating into emergencies. Risk management best practices, however, could have standardized these procedures throughout the organization and prevented the disaster from occurring.

Complying with regulators like the SEC and CFPB
Dwolla, a small, private e-commerce and online payment company, was found by the CFPB to be guilty of risk management negligence for inadequate data security practices. The catch is that Dwolla did not suffer a data breach and none of its customers were compromised.
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The CFPB fined Dwolla $100,000 as part of its increased focus on companies’ existing prevention strategies. Regulators are no longer simply pursuing organizations that have suffered risk management incidents; organizations need to take proactive approaches rather than simply hope to get by.

Improving productivity and encouraging innovation
An independent, peer-reviewed report, “The Valuation Implications of Enterprise Risk Management Maturity,” published in The Journal of Risk and Insurance, proved that organizations with mature ERM programs (as defined by the RIMS Risk Maturity Model) can achieve a 25% firm valuation premium over those without. Risk management does not have to be a burdensome addition to daily responsibilities—and if it is executed properly, it won’t. It simplifies daily operations by increasing transparency and allowing more resources to be devoted to value-add activities, like product development and customer services.

Checklist for evaluating your risk management efforts

A better question than “does my organization perform risk management?” is “how effectively does my organization identify and mitigate risks?” The following checklist outlines characteristics common to effective risk management programs. Your organization should prioritize development in these areas.

  1. Effective risk management governance

Boards, through their risk oversight role, are accountable for a risk’s material impact, whether the cause is at the executive level or on the front lines. The SEC considers “not knowing about a material risk” negligence, which carries the same penalties as fraud.

  • The board must monitor the effectiveness of the organization’s risk management process, ensuring it reaches all levels and business areas.

  • Internal auditors must independently confirm the board is informed on all material risks.
  • All material risks must be disclosed to shareholders, along with evidence that they are effectively mitigated.
  1. Performance management and goal management
  • Divide corporate objectives into business-unit contributions.
  • Identify business processes contributing to a goal within each business unit.
  • Cascade goals to all front-line managers within contributing processes.

  • Aggregate goal assessments and determine links between contributing business processes.
  1. Consistent risk identification and prioritization

Risk assessments must address more than high-level concerns. Effective assessments drill into risk events, uncovering the root cause, or problem “driving” the risk. Repeatable risk assessments are based on common numerical scales and scoring criteria across departments.

  1. Actionable risk tolerances

Risk appetite is a high-level statement that serves as a guide for strategic decisions. In order to be actionable, it should be accompanied by its quantitative cousin, risk tolerance. Risk tolerance is an effective monitoring technique for key performance goals and risk metrics.

  1. Centralized risk monitoring and control activities

Risk managers need to do more than design processes to identify risks and appropriate responses. A critical third component—monitoring—is the verification of a control’s effectiveness over the risk. A few key things to keep in mind to make monitoring effective:

  • Adjust risk assessments over time (spend less time on risks with decreasing indexes).
  • Reduce testing by identifying areas that can share controls (increase organizational efficiency).
  • Link risks and activities to determine which processes need to be monitored (prioritize activities/initiatives).
  • Monitor business metrics (discover concerning trends before they affect the organization).
  1. Forward-looking risk and goal reporting and communication

In order to continue funding their organizations’ risk management programs, boards need evidence that those programs are working. Risk managers should ask two basic questions before reporting to the board:

  • How might identified risks affect the board’s strategic objectives and key concerns?
  • Which metrics or trends most validate the program’s effectiveness?

These items are just a starting point for an analysis of your organization’s program. For a more in-depth blueprint and “state of ERM” report, take the RIMS Risk Maturity Model (RMM), a free best-practice assessment tool that scores risk management programs and generates an immediate report of your organization’s risk maturity.

Building a Successful ERM Program

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Iman H. Al-Gharabally is responsible for the enterprise risk management program at Kuwait Petroleum Corporation (KPC) and its subsidiaries since 2004. She is the team iman-h-al-gharabally-picleader, coordinator and project manager for the ERM program and its strategic implementation across the Kuwait oil sector. Al-Gharabally, a speaker at RIMS’ Middle East Risk Forum 2016, taking place Dec. 13 and 14 in Dubai, United Arab Emirates, discusses the implementation strategies and successes of KPC’s ERM program.

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RIMS: How did you begin the process of building KPC’s ERM program?

Al-Gharabally: In 2002 the KPC managing directors at the time recognized there was a serious need to look into and have in place a consolidated view of potential risks and a consolidated risk management format of those risks facing the organization. Hence the ERM initiative was introduced as a way to instill this unified format of consolidated risk management mainly through the insurance section. In 2004 the ERM initiative was introduced and in 2006 the ISO 31000 was launched.

RIMS: How did you develop your ERM structure?

Al-Gharabally: Initially I had no prior knowledge of what ERM stood for. I was recruited in April 2004 from Kuwait Oil Company (a subsidiary to KPC) to project manage and lead this new ERM initiative. I studied the topic extensively and slowly had to lay down the foundation for a dynamic ERM program for KPC and its subsidiaries. We started at the very top, first in the corporate office looking at the strategy of the corporation and what the corporate objectives aimed to achieve in the coming five years from 2004 to 2009. We then looked at the potential risks that would prevent the corporation from achieving those objectives and started the communication lines across the subsidiaries to initiate awareness on these potential risks and put forth mitigation options to ensure the corporation was well prepared and to increase our abilities to deliver on our strategic objectives.

It was imperative at the very beginning to ensure that we worked hand-in-hand with the various planning, HSE and marketing units across the entire value chain. The idea was to start the conversations early and brainstorm unilaterally for solutions to be placed to counteract any potential risks emerging that would hinder our 2020 strategic business goals.

Over the first few months in 2004, we managed to convince CEOs across the group to create and assign a focal point to be internally responsible for ERM and coordinate and liaise with us at the corporate head office on all ERM related matters. It took 10-12 months before having each subsidiary assign a dedicated ERM focal point. Once there were dedicated individuals to communicate with and be internally responsible for monitoring and reporting on all risk-related matters, the next phase of setting up an ERM framework and governance structure was initiated. In 2007 the ISO 31000 framework was launched across the group for implementation.

KPC’s ERM structure is that of a hybrid matrix in which central ERM policies, procedures and key performance measures are set, while subsidiaries and ERM units across the group are free to implement according to their individual company’s needs and business model.

RIMS: How did you make ERM a success?

Al-Gharabally: It was not an easy task, to be honest. KPC is the corporate head office to eight other companies from upstream to downstream. The nature of their business is quite complex and diversified. So to lead ERM initiatives and have them fully incorporated and periodically monitor and report on the progress is a challenging full time task. The key is to be well integrated.

From the very start of our initiative in 2004 we made certain that the corporate head office ERM unit was well integrated with each and every single subsidiary ERM unit. We put in place a platform establishing a community of ERM best practice and there are means to discuss, troubleshoot and share various topics to ensure the benefit is widely absorbed across the entire oil sector. We conduct periodic risk culture surveys and benchmark ourselves not only internally across the group, but also against international financial and oil corporations with advanced risk management programs.

RIMS: What is unique about KPC’s approach to ERM?

Al-Gharabally: Having an ERM program in place in an oil corporation is in itself unique. To take that further and have a single unified ERM strategy and shared initiatives across multi discipline functions and across eight subsidiaries elevates the uniqueness. Having delivered a successful fully functioning ERM program over the past 13 years in close collaboration with the corporation’s strategic planning, financial and marketing departments sets KPC’s ERM program apart.

RIMS: What tools/resources have been the most helpful on this journey?

Al-Gharabally: From a risk culture perspective, establishing a community of best practices for ERM individuals to have a platform to share and collaborate various ideas, trouble-shoot implementation issues or integrate objectives on unilateral ERM implementation plans is critical to the success of our program. Having a risk operating committee chaired by the CFO and reporting to the corporation’s risk and audit committee was also a critical success factor to KPC’s ERM initiative. Subsidiaries learned early on that having a dedicated ERM unit reporting directly to the CEO, with no conflicts of interest of shared ownership of risks in the reporting line, was a critical success factor to KPC’s ERM structure. From a technical perspective, establishing a clear ERM framework, policy and procedure as well as systematic reporting of risks in a unified ERM information system, and linking the reporting to the corporations was a critical success factor.

Rims: How can ERM best inform strategy?

Al-Gharabally: KPC’s decision to maximize transparency and work closely with strategy marketing and finance was a key aspect in making our ERM program successful. To be able to look at leading risk indicators and have in place the appropriate mitigation options for improving the corporation’s performance in meeting its strategic objectives is an invaluable resource.

RIMS: What advice can you give those embarking on building a world-class ERM program?

Al-Gharabally: Communication, communication, communication! Had we not lobbied, or brainstormed across various business functions early in our journey in 2004, or not ensured that we had the full support of planning and finance on board for our ERM initiatives, our program most likely would have flopped!

Retail Data Security: Preparing for the Top Threat for Holiday Breaches

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Here’s the question of the season: What is the true cause of the retail breaches we read about year after year? While malware or ransomware may get most of the scary security press, they aren’t in fact the main culprit. The primary cause of most retail breaches is, by far, stolen credentials. These are the usernames and passwords of employees, contractors or partners of a retail firm. Victim firms such as Target Corp., Home Depot, eBay and others have fallen prey to similar attacks in recent years: a trusted insider’s credentials were stolen and hackers used those to access the network. In some cases, the credentialed access led to the installation of malware on card reader systems, while in others, hackers took different paths.

The point is clear, however: the access credentials of trusted insiders are in fact the biggest risk factor for a breach in the retail sector. Verizon’s annual data breach survey, released earlier this year, confirms this, with credential attacks identified as the top source of data breaches as 63% occurred via weak or stolen credentials.

This isn’t a particularly new insight. The Target and Home Depot breaches, both via stolen vendor credentials, happened more than two years ago.

And yet, as the Verizon report indicates, large firms are still quite vulnerable to credential attacks. Why is a credential-based attack so hard to detect? The point of the attack is to impersonate a valid user (an employee, contractor or some other insider) going about his or her daily job. When a financial analyst logs into a financial system using her regular ID and password, for example, we do not expect an alarm to sound.

The retail environment has some unique factors that make detection more difficult.

For example, retailers employ large numbers of seasonal workers, so knowing whether a particular person should be allowed near a secure server in the back room of a store may be difficult. The general buzz and chaos in retail stores may weaken security checks, and sheer volume of transactions, returns, special orders, and the like can distract employees and open up security gaps.

There are, however, concrete steps that can be taken.

The first is simple: most if not all retailers have two networks, one corporate and one retail (in-store). Human resources, research and development, accounting, and other corporate functions operate on the corporate network. Point of sale systems, cashiers, and store managers operate on the retail network. In theory, these networks are completely walled off from each other, using two-factor authentication and other security systems. A temporary sales clerk should not be able to access the payroll system at corporate headquarters and download employee social security numbers, just as an HR specialist at headquarters should not be able to access the credit card database within a store point-of-sale (POS) server. This is especially sensitive since many retailers haven’t yet rolled out chip-and-pin readers. If a card number is stolen from a POS system, it’s usable in many places.

A basic check would be to ensure that the two-factor authentication system between the corporate and retail networks is working correctly, is updated with patches, and is applied as broadly as possible. However, this is not always the case, and there have been instances where hackers have been able to steal a corporate user’s credentials (using a keylogger or other type of malware) and then bypass the authentication system to connect to hundreds of in-store POS systems. Perhaps the system configuration has “drifted” over time and needs re-certification. This is an easy check on network security risk.

Another step relates to context—in other words, understanding what is normal. As mentioned above, a retailer during the holiday season manages chaos on a daily basis. It is too easy for attacks to slip by without notice during the noise and commotion. Recall the advice given to New Yorkers after 9/11: “If you see something, say something.” While relying on employees to notice unusual behavior is fine, a better approach is to augment humans with smart technology that understands normal behavior and can raise an alarm when behavior is suddenly not normal.

For example, a specialist in IT is accessing hundreds of POS systems in multiple stores via the corporate network. Is that okay? It is hard to say. Perhaps he is doing it as part of a backup process or maybe he is helping restore systems after a failure. Without knowing what is normal for this person, as well as for his peers, it is very difficult to judge the riskiness of his actions. Behavioral analytics systems are built for this problem. They analyze past behavior and build baselines, just as VISA and MasterCard do for every credit card owner. When an employee suddenly starts logging into store POS systems but has never done so before, behavioral baselines can provide the context needed to alert that this user might in fact be a hacker.

Retailers are getting better about security every year, improving risk management processes and rolling out new security technologies. Credential attacks remain the top threat for retail breaches, however, and retail firms must both verify their processes and also look to new solutions, such as behavioral analytics, to close the risk gap.