Most risk managers will start from the G30 recommendations and other derivative
market control frameworks to set their ‘best practice’ standards for middle-office
controls. However, once you are beyond setting up an independent reporting line
they fall short of specific advice on detailed procedures and controls.
The starting point in defining the framework is a consistent Scheme of Authority
and Trading Compliance Guidelines. These will draw upon the existing corporate
scheme, but need to be radically expanded for the energy trading business. Perhaps
more important is to develop a process to ensure traders and risk managers alike
are aware of the controls and how they impact on their day-to-day work. Once the
high-level control environment has been established the difficult problem of product
authorization should start.
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