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RISK MANAGEMENT IN ISLAMIC BANK

MD AROP OTHMAN RISK MANAGEMENT DIVISION BANK ISLAM MALAYSIA BERHAD 15 NOVEMBER 2007

Bank Islam reserves all propriety rights to the contents of this Presentation. No part of this Presentation may be used or reproduced in any form reproduced without Bank Islams prior written permission permission. This Presentation is provided for information purposes only. Neither Bank Islam nor the Presenter makes any warranty, expressed or implied, nor expressed assumes any legal liability or responsibility for the accuracy, completeness or currency of the contents of this Presentation. Presentation.

STRICTLY PRIVATE & CONFIDENTIAL

Content
Introduction to Risk Management Risk Management for Islamic Banks Principles of Risk Management g Risk Management in Bank Islam

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INTRODUCTION TO RISK MANAGEMENT


Concept of risk management Definition of risk Risk management process Impact of poor risk management p p g

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Concept of risk management in Islam


Text in Al-Quran

O my children, do not enter the capital of Egypt by one gate but go into it by different gates. However, know it well that I cannot ward off you Allahs will for none other than He has nay authority whatsoever. In Him I have put my trust and all who want to rely upon anyone should put their trust in Him alone alone. (Surah Yusuf: Verse 67)

Hadith from Prophet Muhammad s a w s.a.w


Prophet (peace be upon him) once asked a Bedouin who had left his camel untied, Why do you not tie your camel? The Bedouin answered, I put my trust in God The Prophet PBUH then said tie up your camel first then put your God. said, tie trust in God.
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What is risk?
Risks are uncertain future events which could influence the achievement of the Banks objectives, including strategic, operational, fi ti l financial and compliance objectives. i l d li bj ti

Uncertain future events could be: Failure of a borrower to repay a financing Fluctuation of foreign exchange rates Fraud, incomplete security documentations, etc Non-compliance with shariah law and principles Other events that may result in a loss to the Bank

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What is risk management?


Risk management is the process by which various risk exposures are (1) identified, (2) measured/assessed, (3) mitigated and controlled controlled, (4) reported and monitored.

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Lesson learnt from poor risk management


1. Barings Bank - Nick Leeson singled handedly destroyed a bank 2. Sumitomo 2 S it - The trader hid the losses while trading in the copper futures - The company loss USD2.6 b 3. Daiwa Bank - The trader hid the losses while trading in bond market - The bank lost USD1.1 b USD1 1 4. Orange County - There was lack of management control over the trader - The company lost USD1.69 b in the derivatives market

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RISK MANAGEMENT FOR ISLAMIC BANKS


Islamic banking business activities Risks inherent in Islamic banking business Uniqueness of Islamic banking Risk issues for Islamic banks
Shariah non-compliance risk Rate of return risk/Displaced Commercial risk Inventory risk Completion risk Risk transformation at different stages of contract

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Islamic banking business activities

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Balance sheet of Islamic bank


Profit & Loss Revenue Customer Financing Balance Sheet Islamic bank Deposit Dividen/Hibah Depositors

Assets Asset-backed transactions Murabahah/Ijarah/Istisna/Salam Profit sharing transactions Mudharabah/Musharakah Fee based services

Liabilities Demand deposit Investment accounts Mudharabah Special investment accounts Mudharabah/Musharakah Equity
Off Balance Sheet

Restricted investments

Direct investors
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Risk profile of Islamic bank


Shariah non-compliance risk Displaced Commercial risk Equity Investment risk Islamic bank Credit Risk Operational risk

Uniq que

Rate of return risk

Gene eric

Market risk

Liquidity risk

Strategic

Legal

Fiduciary

Reputation

Transparency

Regulatory compliance

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Generic risks for banks


Types of risks Credit risk Definition The potential that a counterparty fails to meet its obligations in accordance with agreed terms and conditions of credit-related contract The potential impact of adverse price movements such as benchmark rates foreign exchange rates equity prices on rates, rates, the economic value of an asset The potential loss arising from the Banks inability either to meet i obligations or to f d i its bli i fund increases i assets as they in h fall due without incurring unacceptable costs or losses The potential loss resulting from inadequate or failed internal processes, people and system or external events

Market risk

Liquidity risk

Operational risk

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Risks transformation for financing of assets


Even generic risks are not straight forward in Islamic banking For financing that involves financing assets eg Murabahah, Salam, Istisna and Ijarah, the risks of financing may transform from credit to market and vice versa at different stages of contract Hence capital requirement needs to take into account both the credit and market risk

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Risk transformation under Murabahah & MPO


Murabahah Bank ll M b h h B k sells assets it already owned t customer at cost + t l d d to t t t Murabahah Purchase Orderer (MPO) Bank sells assets it acquires to customer at cost + based on promise to purchase (PP) by customer
Type of contract Murabahah and non binding non-binding Murabahah purchase order Stage of contract Asset available for sale (asset on balance sheet) Asset is sold to and payment is due from customer Maturity of contract or upon full settlement Binding Murabahah Purchase Order Asset available for sale (asset on balance sheet) Asset is sold to and payment is due from customer Maturity of contract or upon full settlement
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Credit risk X X X -

Market risk X -

INCEIF-LOFSA WORKSHOP, LABUAN

Risk transformation under Ijarah & IMB


Ijarah Bank owns the assets whilst transferring the right to use the asset to lessee. Liabilities & risks pertaining to the th asset i b t is born b B k by Bank IMB Bank promise to transfer the asset by sale or hibah & MUST be separately expressed and independent of underlying Ijarah

Type of contract Operating Ijarah

Stage of contract Asset available for lease (prior to signing of a lease contract) p g g g Upon signing a leasing contract and the asset is available for lease Maturity of contract term and the leased asset is returned to the bank

Credit risk X X

Market risk X X X X -

Ijarah Muntahia Bittamleek

Asset available for lease (prior to signing of a lease contract) Upon signing a leasing contract and the asset is available for lease Maturity of contract term and the leased asset is sold and the ownership of asset i t hi f t is transferred t f d to the customer
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Unique risks for Islamic banks


Types of risks Shariah noncompliance risk p Rate of return risk Displaced Commercial risk Definition Risk arises from the failure to comply with the Shariah rules and principles p p The potential impact on the returns caused by unexpected change in the rate of returns The risk that the bank may confront commercial pressure to pay returns that exceed the rate that has been earned on its assets financed by investment account holders. The bank foregoes part or its entire share of profit in order to retain its fund providers and dissuade them from withdrawing their funds. The risk arising from entering into a partnership for the purpose of undertaking or participating in a particular financing or general business activity as described in the contract, and in which the provider of finance shares in the business risk. Thi risk i relevant under M dh b h and b i i k This i k is l t d Mudharabah d Musharakah contracts.
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Equity Investment risk

Salient features of Islamic banking


Prima-facie Prima facie free from prohibitive list as prescribed clearly by Shariah Shariah.
FEATURE WHY?

1. Interest (riba)-free (riba) free

Money is just a medium of exchange. It cannot earn more money by itself without putting it into real productive actions. Avoid any dispute due to unfairness in dealing caused by the lack of knowledge. Zero-sum game wherein it just transfers the wealth, not creating new wealth. Religious and ethical value consideration or public policy. To ensure every contract behaves in its proper context. This does not negate freedom of contract (hurriyah l t (h i h al-taaqud) d)
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2. Uncertainty or lack of knowledge (gharar)-free 3. Gambling (maysir)-free 4. Not involved in selling or leasing or partnership in something is impure or not halal 5. Not in direct conflict with established Shariah principles in muamalah.

Examples of Shariah issues


Completeness of aqad (contract) risk Murabahah Contract Basic tenets 1. 1 2. 3. 4. 4 1. 2. 3. 4. Seller Buyer Asset to be transacted Aqad offering and acceptance The original price of the asset is known to the buyer p p y Transparent in terms of profit to be taken by the seller Payment must be made with something of legal tender value Not ribawi commodities

Additional requirements

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Examples of Shariah issues


1. Wadi ah: 1 Wadiah:
Disclosure of the hibah on the rate board, website etc. Gift to depositors Shariah non-compliance fund

2. 2 Mudharabah (deposit)
Guarantee on the capital and return Maintenance cost on the Mudharabah deposit account Shariah non-compliance fund

3. 3 Remittance
Shariah non-compliance fund

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Examples of Shariah issues


4. Sale (Bai Inah & BBA)
MPO Ownership of the asset prior to sale aqad Inter-conditional Inter conditional clause between ASA & APA The word agree in the aqad Financing of non-Shariah compliant asset Financing of asset intended for non-Shariah compliant activities

5. AITAB
Appointment of customer as the Banks purchasing agent prior to Ijarah contract Maintenance cost during Ijarah tenure

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Examples of Shariah issues


6. 6 Trade Financing d i i
Commitment fee on the unutilized line BG guarantee of non Shariah compliant asset, activities etc asset etc.

7. Refinancing
Refinancing of encumbered property

8. Recovery
Repossession - BBA

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Implications of Shariah non-compliances nonNon Financial Impacts


Against the commands of Allah. Impediment from Allahs blessing or barakah b k h Contravention of the provision of Islamic Banking Act 1983 (Section 3(5)(a) Section 3(5)( ) & S ti 4) Jeopardize the Banks reputation as an Islamic bank

Financial Impacts
Invalidation of contract (aqad) Non-halal income Capital adequacy ratio (CAR) Impact

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Rate of Return Risk


Associated with the management of assets and liabilities Fixed rate long term assets funded by variable rate short-term liabilities Movement in b M t i benchmark rates may result i f d providers h i h k t lt in fund id having expectations of a higher rate of return Subsequently, it may result in displaced commercial risk where due to market pressure, Islamic bank needs to pay a return that exceeds the rate that has been earned on its assets. If Islamic bank does not yield to market pressure, they may lose their fund providers which could consequently lead to liquidity risk

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Profit distribution
Income from investment Income from financing Income from IMM investing

Gross Income Less: Net trading income and other income Financing and investment loss provision Profit equalisation reserve Direct expenses Net Distributable Income

Profit Sharing Ratio Investment Risk Reserve


Depositor Islamic bank

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GUIDING PRINCIPLES OF RISK MANAGEMENT


BASEL Committee on Banking Supervision Islamic Financial Services Board (IFSB) Bank Negara Malaysia

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BASEL
1988 Capital Accord (Basel I)
Regulatory based Set out requirements to calculate capital charge ie the amount of capital to be set aside to absorb potential loss across banks and across countries One size fits all

1996 Basel I (Amendments)


Market Risk was incorporated into Basel I

2004 International Convergence of Capital Measurement and Capital g p p Standards (Basel II)
Aims to make capital requirements more risk sensitive Includes Operational Risk Bank shall be subject to 3 mutually reinforcing pillar
Pillar 1: Minimum Capital requirements Pillar 2: Supervisory Review Process Pillar 3: Market Discipline

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IFSB
2005 Guiding Principles of Risk Management 2005 Capital Adequacy Standard 2006 Corporate G C t Governance 2007 Supervisory Review Process 2007 Transparency and Market Discipline

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IFSB Guiding Principles of Risk Management


15 guiding principles which cover q g process (1) ( ) General requirement for an effective risk management p Credit risk (4) Equity Investment Risk (3) Market Risk (1) Liquidity Risk (2) Rate of Return Risk (2) Operational risk (2)

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IFSB Guiding Principles of Risk Management


General requirement p p p g Principle 1.0 IIFS shall have in place a comprehensive risk management and reporting process, including:
Appropriate Board and Senior Management oversight Identify, measure, monitor, report and control relevant categories of risks Held adequate capital against risk Comply with Shariah rules and principles Adequate risk reporting to the supervisory authority

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IFSB Guiding Principles of Risk Management


Shariah non-compliance p p q y , Principle 7.1 IIFS shall have in place adequate systems and controls, including Shariah Board/Advisor, to ensure compliance with Shariah rules and principles Requirements:
IIFS shall ensure that they comply at all times with the Shariah rules and p principles p IIFS shall ensure that their contract documentation complies with Shariah rules and principles IIFS shall undertake a Shariah compliance review at least annually IIFS shall keep track of income not recognised arising out of Shariah noncompliance and assess the probability of similar cases arising in the future

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IFSB Guiding Principles of Risk Management


Rate of return risk p p g Principle 6.1 IIFS shall establish a comprehensive risk management framework and reporting process to assess the potential impacts of market factors affecting rates of return on assets in comparison with the expected rates of return for investment account holders Principle 6.2 IIFS shall have in place an appropriate framework for managing displaced commercial risk, where applicable g g p , pp

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IFSB Capital Adequacy Standard


The Th need for RWCR framework df f k To ensure that Islamic banks can absorb a reasonable level of losses before becoming insolvent. To provide protection to depositors and/ or PSIA the higher the CAR, the higher the level of protection. To T promote stability and efficiency of the fi bili d ffi i f h financial system b reducing the i l by d i h likelihood of Islamic banks becoming insolvent. To ensure that the Islamic banks capital p p position commensurate with its overall risk profile and strategy.

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IFSB Capital Adequacy Standard


IFSB RWCR - Standard Formula
Eligible Capital Total RWA (Credit + Market Risks) + Operational Risk Less RWA funded by PSIA (Credit + Market Risks) > 8.00%
PSIA is Profit Sharing Investment Account

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IFSB Capital Adequacy Standard


IFSB RWCR - Supervisory Discretion Formula
Eligible Capital Total RWA (Credit + Market Risks) + Operational Risk Less RWA funded by Restricted PSIA (Credit + Market Risks) Less (1 )[RWA funded by Unrestricted PSIA (Credit + Market Risks)] Less [RWA funded by Profit Equalisation Reserve (PER) and Investment Risk Reverse (IRR) of Unrestricted PSIA (Credit + Market Risks)]

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RISK MANAGEMENT IN BANK ISLAM


Risk Management Framework Organisational Structure Policy and Guidelines Enablers

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Risk Management Framework (RMF)


Providing an architecture that governs the overall risk management philosophy and strategy Acting A ti as a f foundation t allow management of risks t b conducted most d ti to ll t f i k to be d t d t effectively in line with the industrys best practices Setting a tone for the philosophical and practical approaches in managing risk

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Concept & Methodology


SOLAH THE PILLAR OF ISLAM NIYYAH
Pronouncement/ Statement of Solah

PHILOSOPHY OF SOLAH IN LIFE


MISSION STATEMENT

BANK ISLAMS RMF

MISSION & OBJECTIVES

JAMA AH JAMAAH
Implementation Structure of Solah

STRUCTURE

FUNCTIONAL STRUCTURE

SYARAT
Necessary Elements of Solah

RULE OF LAW

POLICIES & GUIDELINES

RUKUN
Essential Activities of Solah

PROCEDURE

PROCESSES

QAEDAH
Facilities Required for Solah

TOOLS

ENABLERS

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Functional Structure
Shariah Supervisory Council (SSC) BOARD OF DIRECTORS Other Board Committees Board Risk Committee (BRC)

Constitution Function

As per BNM guidelines Risk Mgmt Oversight and Over-riding authority for Risk Mgmt Approval of RMD S b i i A l f Submissions

SHAREHOLDER MANAGEMENT Internal Audit Department

Board Financing Review Committee (BFRC)

Managing Director

Functional Administrative

Business Units

Other Management Committees

Financing Committees (FCA, C , C) ( C , FCB, RFC)

Management Risk Control Committee ( (MRCC) CC) Risk Management Division (RMD)

Business Support Units Asset Liability Committee (ALCO) Other Corporate Support Units Credit Risk

Market Risk

Credit Administration

Credit Analysis

Business Risk Control & Compliance

Shariah Compliance Risk Operational Risk

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Policies & Guidelines


Policies for principle risk areas are in place covering areas of credit, market, operational and Shariah compliance Policies are supported by Guidelines and further supported by operational manuals to ensure policies are implemented properly Approving authority
RMF Board Policy Board Guideline MRCC Manual - Stakeholders

All policies, guidelines and manuals are reviewed annually to ensure consistency and in line with business reality

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Credit risk
Policy Credit Risk Policy - The policy addresses the broad credit management framework that covers the objective, strategy, structure and credit processes in order to establish the best practices in the management of credit risk that are in line with the regulatory requirements. Guidelines
1. Pricing Matrix Guidelines 2. Acceptance Letter Offer Guideline 3. Negative List Guideline 4. Collaterals Guideline 5. Valuation Guideline 6. 6 Discretionary Power Guideline 7. Sovereign Risk Guideline 8. Consumer Grading Guideline 9. Sectoral Guideline 10. Business Relationship Etiquette Guideline 11. Watchlist Guideline 12. Financing P 12 Fi i Process G id li Guideline 13. Credit Recovery Guideline 14. Guidelines on Risk Adjusted Pricing for Corporate & Commercial p

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Market risk
Policy Guidelines

Market Ri k Policy Describes the Ri k P li M k t Risk P li D ib th Risk Policy and Analytics, Asset and Liability Management (ALM) and Middle Office functions of the Market Risk Department Trading Book Policy - Addresses market risk factors which include but not limited to profit rate or rate of return, foreign exchange, equity and commodity risks inherent in the Banks trading and banking books

1. 1 2. 3. 4. 5. 6.

Market Risk Limits Guideline Hedging Guideline Mark-to-Market Guideline Rate Reasonability Check Guideline y Value-at-Risk (VaR) Guideline Asset and Liability Management Guideline 7. 7 Market Risk Manual & Procedures

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Operational risk
Policy Guidelines

Operational Ri k P li Th policy provides O ti l Risk Policy The li id the effective and efficient operational risk management through out the Bank through its strategies in terms of organization structure, process, risk tolerance, risk measurement and i kt l i k t d analytic model management information system

1. 1 2. 3. 4. 5. 6. 7. 8.

Operational Risk Management Guideline Management Awareness and SelfAssessment (MASA) Reporting Guideline Fraud Handling and Reporting Guideline g p g Takaful/Insurance Guideline Key Risk Indicators (KRIs) Guideline Outsourcing Guideline Operational Risk Management Process for Information Security Management System 9. Customer Complaint Guideline 10. BRCP

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Shariah compliance risk


Policy
Shariah Compliance Risk Management Policy The policy provides the Shariah requirements applicable throughout the Bank in its activities, products and services in compliance with the Shariah principles, provisions of the Islamic Banking Act 1983 and Bank Negara Malaysias rules and regulations.

Guidelines
1. Wadiah Contract Guideline. 2. Ijarah and Ijarah Muntahiah Bit Tamlik Guideline 3. Murabahah and MPO Contract Guideline 4. Mudharabah (financing) C t t G id li 4 M dh b h (fi i ) Contract Guideline 5. Musharakah (financing) Contract Guideline 6. Handling and Reporting of Shariah Non Compliances Guideline p 7. Mudharabah (Deposit) Contract Guideline 8. Musharakah Mutanaqisah Contract Guideline 9. Dhamanah/ Kafalah Contract Guideline 10. Wakalah Contract Guideline 11. Tawarruq Contract Guideline

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Process of risk management


Awareness & Identification
Knowing what the risks/risk areas are

Assessment & Measurement


Analytical ability to assess & measure risks

Mitigation & Control


Identifying & applying appropriate mitigations & controls of identified y g pp y g pp p g risks/risk areas

Monitoring & Reporting g p g


Continuous monitoring & appropriately reporting identified risks/risk areas

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Enablers
Tools to assess and monitor risk issues include:
Key Risk Indicator (KRI) Management Awareness and Self Assessment (MASA) Risk Profiling Portfolio / Exposure tracking Customer Ratings Value at Risk (VaR)

Systems to manage risk issues y g


Core Banking and Middle-wares Financing Origination & Collection Systems Treasury Middle Office systems - QRisk, Quantum y y Q ,Q Operational Risk Management System Administrative systems

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Managing Shariah non-compliance risk nonFunctional structure F ti l t t


Shariah Supervisory Council

Shariah Department Shariah Audit Unit of h IAD Ext ternal Audit/ BNM / Audit Audit Examinatio on Co ommittee

Shariah Compliance Risk Mgmt Shariah Compliance p Risk Working Group Board Risk Committee

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Managing Shariah non-compliance risk nonFunctional structure


Function Shariah Supervisory Council C il Shariah Department SCRM Department Key Roles and Responsibilities/ Remarks Structurally reports to Board, but functionally is independent of the Board and management of the Bank. Governed by BNM GPS1 Support the SSCs function on day-to-day basis Providing Shariah advice based on the decisions of Shariah councils Conducting training C d ti t i i on Sh i h related matters. Shariah l t d tt Third layer of control mechanism after SSC and SD. Facilitating the process of managing SCR in the Bank. Formulating SCRM policy and guidelines Performing independent evaluation on products, manual & guidelines Monitoring SNC and keeping track of income arising from SNC Identifying internal control weakness and recommending mechanism to address the SNC. Sub-committee of Management Risk Control Committee established to be responsible for developing the SCRM capability of the Bank. Chairman: GM CABD D Ch i CABD, Deputy Ch i t Chairman: CRO S CRO, Secretary: H d of SCRMD and t Head f d members: Senior officers from Business and Support Units.
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Shariah Compliance Risk Working Group

Managing Shariah non-compliance risk nonAwareness & Identification A Id tifi ti


Conduct Shariah awareness program to all staff Incorporate Shariah requirement in operational manuals Newsletter on quarterly basis Risk portal

Assessment & Measurement


Develop Shariah compliance risk scorecard Shariah assessment on new products, initiatives, manuals

Mitigation & Control


Issue policy and g p y guidelines Establish Shariah Compliance Risk Working Group Shariah representative in all committees Require sign off

Monitoring & Reporting


Shariah non-compliances tracking report Key Risk Indicators Monthly reporting to MRCC and BRC y p g

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Key Risk Indicators Report


SNC is one of the Bank s Key Risk Indicator (KRI) parameters. Banks parameters Objectives of the parameter: To promote better understanding of Shariah compliance. To provide a benchmark in determining the level of SNC. Shariah non-compliance is ZERO TOLERANCE RATING 1 2 3 4 5 DEFINITION Very Satisfactory Satisfactory Fair Unsatisfactory Very Unsatisfactory U i f DESCRIPTION No potential SNC case being reported to SCRMU. SCRMU Detection of 5 cases of PSNC. Detection of 6 - 10 cases of PSNC. Detection of > 10 cases of PSNC. Confirmation of at least 1 SNC by SSC.

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Shariah compliant is crucial


Original basis for having a banking system that meets the religious requirements of Muslim in line with their Aqidah. Factor th t distinguishes I l i b ki f F t that di ti i h Islamic banking from conventional b ki ti l banking. Ensures acceptance, validity and enforceability of contracts from Shariah point of view view. Fulfills the objectives of Islamic finance i.e. to achieve justice (adalah) and fairness (musawah) in the distribution of resources.

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Thank You


Wassalam
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