COO Magazine

2023 Year End Special

How to avoid the inevitable

Operational Resilience • Non-Financial Risk • Emerging Risk Assessment • Horizon Scanning

Expecting the unexpected

2024 operational resilience takes permanent residency on the COO’s agenda.

Oscar Wilde, the flamboyant and quick-witted Irish poet, playwright, and cultural commenter, had a great quote “To expect the unexpected shows a thoroughly modern intellect.”

Across commerce and industry, and specifically within financial services, a modern intellect is being called upon to devise and execute a plan to meet the challenges of emerged and the emerging portfolio of non-financial risks.

Worldwide regulatory directives have been issued to the financial services sector to establish, embed and be able to evidence operational resilience policies, protocols, and procedures. These are being promoted to ensure companies are prepared for the unexpected through the codification of good business practice, with horizon scanning accompanying emerging risk assessment to enable companies to be on the front foot, providing the gift of time to meet unfolding events.

In the last decade crises appear to cascade with increasing regularity, with the pandemic, the Ukrainian – Russian crisis, recent bank failures, economic uncertainty, and geopolitical unrest gifting operational resilience a long-term tenancy on the COO’s agenda. 

Conversely, it offers iCOOC members a feast of debate and investigation for the year ahead.

Maurice Evlyn-Bufton

CEO, Armstrong Wolfe


Worldwide regulatory operational resilience overview

How worldwide financial regulators such as the Federal Reserve (FED), the Prudential Regulation Authority (PRA), the Financial Conduct Authority (FCA), and regulators in Asia view operational resilience in the financial sector:

1. Federal Reserve (FED): The Federal Reserve, as the central banking system of the United States, has shown a growing interest in operational resilience within the financial sector. They have emphasised the importance of financial institutions maintaining critical operations during disruptions, including cybersecurity incidents and natural disasters.

The FED has issued guidance on business continuity planning and resiliency to ensure that banks and financial institutions can continue to serve their customers and maintain financial stability during adverse events.

2. Prudential Regulation Authority (PRA): The PRA is the UK’s regulatory body responsible for prudential supervision of banks and other financial institutions. They have a strong focus on operational resilience and have introduced regulations and guidelines for banks and insurers to enhance their operational resilience.

The PRA’s approach includes assessing firms’ capabilities to withstand disruptive events, ensuring they have robust risk management practices, and setting expectations for recovery and resolution planning.

3. Financial Conduct Authority (FCA): The FCA is the UK’s financial regulatory body responsible for conduct regulation within the financial sector. The FCA has also emphasised the importance of operational resilience, particularly for firms providing critical financial services.

They have published guidelines for firms to enhance their operational resilience, emphasising the need for comprehensive risk assessments, scenario planning, and clear communication with customers during disruptions.

4. Regulators in Asia: Various regulators across Asian countries have recognised the importance of operational resilience in the financial sector. These regulators may have introduced their own guidelines and requirements tailored to their specific jurisdictions.

Operational resilience requirements in Asia can vary significantly from one country to another, so it’s essential for financial institutions operating in Asia to be familiar with the specific regulations relevant to their location.

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Ad Centrum: Armstrong Wolfe's new worldwide COO DE&I initiative

Armstrong Wolfe confirms key appointments to drive its contributions within DE&I.

The foundations for Ad Centrum were laid in 2016 when Women in the COO Community (WCOOC) was established.

Building on WCOOC’s success and impact, Ad Centrum will extend the reach and influence of the International COO Community (iCOOC) to give worldwide support and thought leadership within DE&I, complementing established programmes already working to address embedded inequalities.

The Ad Centrum Chair and Vice Chair will be engaged, challenged and supported by a council of eighteen buy and sell side global COOs, WCOOC’s Co-Global Chairs will similarly be supported by a dedicated steering group for North America, Europe and APAC, each hosting six regional COOs.

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The COO Debating Society: New York City 2023

Deutsche Bank New York, September 20th 2023

With the backdrop of Central Park, the COO Debating Society was delighted to be hosted by Deutsche Bank at their splendid new office.   

This format was new to the New York business management community, with the room full of 150 in the audience the stage was set for a good evening.

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A fireside Chat with ChatGPT

We took the opportunity to meet ChatGPT, seeking his/her/its views and perspectives on 3 of the key questions facing the COO and Chief Control Officer global community.

The time spent with ChatGPT was limited, providing expansive and detailed answers to each question in less than five seconds.

Allowing for the limited demand on ChatGPT’s time, we were delighted ChatGPT agreed to reconvene quarterly over the next 12 months. Why? We are interested to see if the answers given by ChatGBT in the autumn of 2024 evolve or change with the seasons between now and the summer of 2025.

In tandem, we are equally interested in the views of our membership on ChatGPT’s answers or specifically on ChatGPT.

Please email

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Armstrong Wolfe Partners with Behavox to Elevate Financial Services Oversight with Innovative Product Suite

We are proud to announce a strategic alliance with Behavox, the leading provider of AI-driven compliance solutions. This partnership marks a significant step forward in revolutionizing the financial industry’s approach to risk management and operational oversight.

For over a decade, Armstrong Wolfe has been at the forefront of fostering collaboration within the investment banking COO community. Through its platform, executives have come together to address regulatory and market-wide challenges related to conduct risk. The organization has been a driving force in integrating first-line business risk and control officers into the leadership teams of Corporate and Investment Banking COOs and CEOs.

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AI Showdown: Behavox AI outperforms ChatGPT in compliance

The rapid proliferation of ChatGPT into mainstream use is nothing short of astounding. Just the other day, an Uber driver enthusiastically recommended it to me, swearing by its impressive outcomes. It is evident that increasingly potent AI systems are on the horizon, even as some of the world’s most renowned scientists and business leaders have called for a temporary deceleration in the development of powerful AI models.

This raises the question of how ChatGPT can be utilized within the banking sector, and by extension, in compliance. We’ve already observed in the media that some banks are taking measures to ban ChatGPT, while others are embracing it on an enterprise-wide scale. With the tantalizing promise of AI, numerous compliance professionals are eager to harness its potential to enhance productivity and minimize false positives.

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The Hybrid Working cul-de-sac

Minutes from Online Forum Thursday, 13th July, 2023

The debate around Hybrid working practices remains contentious, with strong beliefs abounding on both sides of the discussion.

The initial shift towards hybrid work was necessitated by the COVID-19 pandemic. However, in the wake of the pandemic, the question is now how to establish Hybrid working in a format that works for employees and employers, bringing the benefits of flexibility and productivity in a sustainable way. The suitability of hybrid work varies for different roles, and there’s a recognition that certain cultural aspects are better fostered in an office setting.

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Parliamentary Report on Changing Banking for Good

A Retrospective View and Update

In the Winston Churchill tradition of “never let a good crisis go to waste”, this report has proved useful in bringing about some positive change. A call for “Better functioning and more diverse banking markets” has been at least partially satisfied.

Accountability has improved and together with some new developments over the past decade in behavioural science and technology, the potential for further improvement is rising. In this article, the Financial Markets Standards Board (“FMSB”), summarises some key factors that were less evident in 2013 but are more advanced now. 

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Reputation, what does it mean to your organisation? And how are you prepared to protect it?

While the terms diversity, inclusion, equity, belonging, accessibility, and justice have long been bounced around and are seen frequently in corporate organisational strategies woven into mission, value, and purpose statements, the real question is whether organisations really understand the meaning behind these words.

Are they merely tokenistic gestures or virtual signalling to show support for an EDI agenda that will never come to fruition? Employee activism and social conscience is by no means a new phenomenon, but the heightening politicisation of ESG in media and increased attention to EDI objectives makes this an important juncture.

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Systemic Misconduct in Financial Services

The focus on misconduct from financial services entities, regulators and public inquiries tends to be on the responsibility of individual organisations and those who manage them.

In contrast, this research examines the lesser explored dynamics of systemic misconduct in the financial services industry. This reflects a situation where separate entities (e.g. banks) share similar behaviour without collaborative intent and interorganisational networks facilitate the spread of unwanted behaviour to the whole system.

In this context, the cause of misconduct is considered a social construct reflective of the “bad barrels” metaphor rather than an individualistic driver represented by “bad apples”.

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Regulation: The Control Officer’s sitting tenant

Since 2015 Armstrong Wolfe’s Global Chief Control Officer community has convened to discuss market wide, non-proprietary challenges.

Debate is provided in a Chatham House Rule environment, which promotes cross table investigations into matters often at the granular level, helping our members validate and address procedural policy making, the challenges of operationalising specific requirements, regulatory interpretation and technological optionality.

This is why we are the trusted partner of the Chief Control Officer.


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Middle Powers: a rising force in the new world order?

The term “middle powers” has been cropping up recently as a way of referring to countries capable of playing key strategic roles internationally or regionally.

While there is no agreed upon criteria of what makes a country a middle power, the concept speaks to a multipolar world that is not dominated entirely by the US and China.

Claudine Fry, Gabriel Brasil and Patricia Rodrigues discuss what makes a country a middle power and what this rising force in geopolitics means for business.

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Build Bridges...Not Walls

CIO’s leading effective business transformation

When moving into the role of a CIO, it’ s easy to fall into the trap of diving deep into technology right from the start. In this age of automation everyone is touting the “buzzwords” of the day – cloud, AI, machine learning, blockchain and overall digital transformation.

It’s easy to get caught in the “weeds of detail” before taking time to consider the overall direction the organisation should take, especially when it needs to evolve significantly.

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Armstrong Wolfe Institute of Leadership and Performance

We are a cooperative venture providing unique integrated leadership and performance solutions to address human resource challenges within global companies.

Our partners are owner managed businesses with a collective entrepreneurial spirit with a vested interest in delivering success and possessing a common purpose to be recognised for excellence.

This excellence comes from a deep-rooted understanding of the sector we operate, the mindset of entrepreneurism and diversity of thought, this born from diverse representation of our leadership by gender, nationality, education, individual careers, and lifetime experiences.

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