Global European Bank


Global European bank with operations in over 67 countries

The Mandate

The client needed to implement a controls framework for compliance with the Volcker Rule. It required the design and implementation of 2nd Line of Defense (SLOD) controls that would be integrated with 1st Line of Defense (FLOD) controls.

Approach and Key Findings

Helping to manage both internal and external resources, the multi-stage approach involved first assessing both existing FLOD and SLOD controls and identifying missing controls and other gaps such as documentation in the framework. The next stage focused on designing the missing controls, drafting process and procedure documents, and recommending enhancements to existing controls with a particular focus on the SLOD controls. The key stakeholders in this stage of work were Market Risk, Compliance, and Product Control. The proposed controls framework was socialized and validated by key stakeholders throughout the enterprise. The controls were then cataloged for final presentation to the client’s primary US regulator.


The Volcker controls framework was completed on a timely basis and met the requirements established by the primary regulator.


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