text_combined: transparently controlling wholesale trading businesses internal approach internal audit shawn shona talked round issue time thought would try take brief stab documenting preferred approach need great deal talking would circulate widely aims accountability internal controls must rest commercial support teams absolutely leaders teams culture control operational risk assessment requires extensive going communication structure measurement tracking independent process review doorstep brm fully leverage work engaged staff line indeed focused elements implementing completing reviewing internal control generate defined output focus independently review efforts trading controls origination controls defined control structure trading offices agency offices origination offices must police labelling office output enron perspective appropriate risk issue lists discussed control governance meetings eg sally ted fernley level audit committee level important issue every list must extracted agreed database issues different lists different amounts filtering applied judgementally senior experienced staff output aa perspective internal controls audit opinion based upon database review management process trading process monthly routine judgemental self assessment areas within trading transaction cycle rating made business controller red amber green trend indicator static improving declining see attachment 2 full listing monthly metrics collected key standards set risk management see attachment 1 notice summarised version attachment 2 senior controller would expect metrics underpin solely drive judgement within self assessment shona work mike moscoso leading periodic review meeting controller commercial lead discuss operational risk areas concern red amber agreement action plans areas monthly review controller senior controller database high red medium amber risk issues recorded milestones action plans revisited reconfirmed amended monthly meeting remote office staff controllers identify risk rating remote offices changed new information issues raised self assessment doorstep review brm completion populated database database utilised globally report various levels governance decision whether original brm doorstep plans require amendment process yearly planning checkpoint taken current operational environment say end oct proposed new offices coming year proposed changes activity office development plans next year prioritisation made doorstep offices require visit depth report need go note doorstep review would end end review entire business unit therefore independent review existing self assessment would leverage work focusing review effort areas concern actions plans place concluding mitigation operational risk acceptable level prioritisation made brm functions business units require external independent review highly leveraging self assessment doorstep processes could aa signoff simply auditing internal governance process likely reviews completed functions assessed concerns across multiple business fx exposure management cash management credit exposure management change management controls process thought immediately bottom operational risk assessment businesses suggesting demand business controllers houston offsite 23 rd oct would validate high level operational risk summary senior controllers could put together audit committee last week oct agree robust tracking process throw one brm doorstep databases november given aa never historically risk rated issues repopulate database scratch november review doorstep plan check risk rating business units remote offices means resource focused correctly need visit november review blend risk based approach brm planning end november end december wow lets chat mike attachment 1 attachment 2 areas judgement proactively made business unit controller business oversight system development project change management people management coaching skills headcount gaps model review stress testing business risk identification operational capacity assessment signoff error management control cycle risk management control recognition risk origination monitoring trading activities limit checking trader mandates specific transaction analysis dash cacs etc transaction capture deal form analysis risk management system input logistics support delivery position analysis incoming outgoing invoice maintenance post deal execution contract management portfolio edits required amendments previously transacted risk contracts market risk position signoff transaction specific portfolio management dpr production signoff limit excession reporting market risk feeds grms review var applicability backtesting credit risk review liaison rac provisioning credit charges price input checking verification reserving income recognition issues weekly executive summary monthly revenue summary documentation documentation generation review contract loading risk management system affirmation chasing broker information reconciliation trade accounting general ledger account ownership balance sheet cpr reconciliation accounts receivable maintenance monitoring accounts payable maintenance monitoring monthly management accounts profit centre business segment inter company inter entity reconciliation differences legal entity balance sheet analysis fin ops settlements outgoing invoice generation incoming invoice reconciliation exchange statements reconciliation otc brokerage charges reconciliation processing nostro reconciliations cash management liaison