Managing Wholesale Market Conduct - Risk Management

On 31 December 2021, Bank Negara Malaysia (BNM) issued “The Wholesale Market Conduct Practices Guidance Document,” a supervisory guidance document that provides practical support to market participants in managing policy, procedures and controls surrounding wholesale financial market conduct risk.

This one-day programme is designed to provide an appreciation of the “The Wholesale Market Conduct Practices Guidance” for those working in financial markets, as well as those working in compliance, risk management, internal audit and other related roles. It will also help raise awareness of participants on the importance of developing a strong ethical culture and internal control environment across the organisation.

The programme will cover good practices in key wholesale market conduct areas such as avoiding market abuse, implementing misconduct risk assessments and governance and oversight frameworks, trade and communication surveillance, internal control and culture aspects. It will also focus on understanding misconduct risks and how to develop and ensure good conduct culture to mitigate non-compliance of conduct rules.

Programme Outline

Learning Objectives

By the end of the programme, participants will be able to:

Have a deeper understanding of BNM’s “Wholesale Market Conduct Practices Guidance Document”
Develop awareness of wholesale market conduct management
Respond to the need to ensure strong conduct and control environment within the organisation

Programme Outline

What is “conduct risk”
Background and development
Key challenges and common failures
Penalties and enforcement actions
Case study: Market abuse and manipulation
Responsibility to preserve an ethical and honest market place
Treatment of reference or fixing rate
Position parking
Dealing at non-current rates
Dealing for personal account
Entertainment and gifts
Anti-Money Laundering and Counter Financing of Terrorism
Case study and exercise: What are the drivers of misconduct?
Sharing of information
Handling of confidential information
Conflict of interest
Case Study: Bank’s “conflict of interest policy” examples
Traceability, auditing and record keeping
Robust and clear policies, procedures and organisational structure
Segregation of duties and authorisation
Confirmation of dealings
Security in dealing area
After-hours and off-premises dealing
Managing conduct risk
Culture
Corporate governance
Conflicts of interest
Incentives and drivers of behaviour
The Role of Culture in Promoting Good Conduct
Remuneration and key performance indicators
Consequence management
Training

Discussion: Actions to improve conduct and culture in financial institutions

METHODOLOGY

Lectures, case studies, exercises and discussions

Participant profile

Treasury, wholesale banking, compliance, risk management, audit personnel and anyone who needs to understand Wholesale Market Conduct and how it impacts his/her job

Trainer

Cheah Wee Leong

Director, Investment Banking at the Asian Banking School

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Cheah Wee Leong

Director, Investment Banking at the Asian Banking School

Cheah Wee Leong is the Director of Investment Banking at the Asian Banking School. He has more than 25 years’ experience working in the banking industry with local and foreign banks in various roles and capacities. A seasoned professional, Wee Leong brings with him broad experience as a former banker and management consultant.

Wee Leong started his career at Citibank in 1993 before joining US management consultancy firm Accenture in 1997. At Accenture, he was involved in managing large bank merger-integration, process re-engineering and transformation projects. He has worked in projects in various countries including Hong Kong, China, Singapore, Indonesia, Thailand, Mauritius and Saudi Arabia.

In 2003, Wee Leong joined CIMB as its Head of Operational Risk Management and led the implementation of the bank's operational risk management and Basel 2 - Operational Risk framework. Subsequently, he assumed various senior roles in Trade Finance, Regional Transaction Banking, Corporate Banking, Treasury and Markets division and Group CEO office at CIMB. His last role at CIMB was as Director, Group Strategy. He has been designing and developing courses and conducting training regularly (covering various topics) with the Asian Banking School since 2017.

Wee Leong holds a Bachelor of Business Administration from the USA and a Master of Business Administration (with distinction) from the Anglia Ruskin University, United Kingdom. He obtained training from the Citibank Asia Pacific Banking Institute in Singapore in 1995. He is a certified Chartered Banker, Finance Accreditation Agency (FAA) Certified Training Professional and a holder of the “Certificate in Climate Risk” (awarded by the Chartered Body Alliance, UK) and PRINCE2 Foundation and Practitioner Certificate in Project Management. Wee Leong completed the “Leading the Sustainability in Transformation in Banking” programme with the Frankfurt School of Finance and Management (1 week course in Frankfurt, Germany) in October 2022.