1st Line Business Controls
Industry Paper

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Developing fresh perspectives in the 3LoD

Since it was first articulated, the Three Lines of Defence model has developed to be almost universally accepted by financial institutions and regulatory bodies across the globe as the standard foundation for risk management frameworks. Yet despite its widespread acceptance, difficulties in defining and implementing the model in practice continue to exist.

Regulators, academics, and industry executives have all highlighted challenges in the application of the Three Lines of Defence model and suggested ways in which some of the inherent structural tensions can be managed.

The work of Armstrong Wolfe’s international COO Community (iCOOC) in 2021, summarised in the report titled ‘The 3 Lines of Defence: A view from the First Line’, pooled the candid views of 29 senior first line of defence representatives from a broad cross-section of international financial institutions.

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