FOR
INTERNAL CONTROL SYSTEMS
IN BANKING ORGANISATIONS
Basle Committee on Banking Supervision
Basle
September 1998
Risk Management Sub-group
of the Basle Committee on Banking Supervision
Co-Chairs:
Mr. Roger Cole – Federal Reserve Board, Washington, D.C.
Ms. Christine Cumming – Federal Reserve Bank of New York
Banque Nationale de Belgique, Brussels Mr. Philip Lefèvre
Commission Bancaire et Financière, Brussels Mr. Jos Meuleman
Office of the Superintendent of Financial Institutions, Ottawa Ms. Aina Liepins
Commission Bancaire, Paris Ms. Brigitte Declercy
Deutsche Bundesbank, Franfurt am Main Ms. Magdalene Heid
Bundesaufsichtsamt für das Kreditwesen, Berlin Mr. Uwe Neumann
Banca d’Italia, Rome Mr. Paolo Pasca
Bank of Japan, Tokyo Mr. Noriyuki Tomioka
Financial Supervisory Agency, Tokyo Mr. Kozo Ishimura
Banque Centrale du Luxembourg Ms. Isabelle Goubin
De Nederlandsche Bank, Amsterdam Mr. Job Swank
De Nederlandsche Bank, Amsterdam Mr. Paul Benschop
Finansinspektionen, Stockholm Mr. Jan Hedquist
Eidgenössiche Bankenkommission, Bern Ms. Renate Lischer
Financial Services Authority, London Mr. Stan Bereza
Federal Deposit Insurance Corporation, Washington, D.C. Mr. Mark Schmidt
Office of the Comptroller of the Currency, Washington, D.C. Mr. Kurt Wilhelm
European Commission, Brussels Mr. Nicholas Cook
Secretariat of the Basle Committee on Banking Supervision,
Ms. Betsy Roberts
Table of contents
Page
Introduction 1
I. Background 6
II. The objectives and role of the internal controls framework 8
III. The major elements of an internal control process
A. Management oversight and the control culture 10
1. Board of directors 10
2. Senior management 11
3. Control culture 12
B. Risk recognition and assessment 14
C. Control activities and segregation of duties 15
D. Information and communication 17
E. Monitoring activities and correcting deficiencies 19
IV. Evaluation of internal control systems by supervisory 23
V. Role and responsibilities of external auditors 26
Appendix I 27
Appendix II 28
Supervisory lessons learned from internal control failures
Framework for Internal Control Systems in Banking Organisations
1. As part of its on-going efforts to address bank supervisory issues and enhance
supervision through guidance that encourages sound risk management practices, the Basle
control systems. A system of effective internal controls is a critical component of bank
management and a foundation for the safe and sound operation of banking organisations. A
system of strong internal controls can help to ensure that the goals and objectives of a banking
organisation will be met, that the bank will achieve long-term profitability targets, and
maintain reliable financial and managerial reporting. Such a system can also help to ensure
that the bank will comply with laws and regulations as well as policies, plans, internal rules
and procedures, and decrease the risk of unexpected losses or damage to the bank’s reputation.
The paper describes the essential elements of a sound internal control system, drawing upon
experience in member countries and principles established in earlier publications by the
Committee. The objective of the paper is to outline a number of principles for use by
supervisory authorities when evaluating banks’ internal control systems.
2. The Basle Committee, along with banking supervisors throughout the world, has
focused increasingly on the importance of sound internal controls. This heightened interest in
internal controls is, in part, a result of significant losses incurred by several banking
organisations. An analysis of the problems related to these losses indicates that they could
probably have been avoided had the banks maintained effective internal control systems. Such
systems would have prevented or enabled earlier detection of the problems that led to the
losses, thereby limiting damage to the banking organisation. In developing these principles,
the Committee has drawn on lessons learned from problem bank situations in individual
3. These principles are intended to be of general application and supervisory
authorities should use them in assessing their own supervisory methods and procedures for
monitoring how banks structure their internal control systems. While the exact approach
chosen by individual supervisors will depend upon a host of factors, including their on-site
The Basle Committee on Banking Supervision is a Committee of banking supervisory authorities which
was established by the central bank Governors of the Group of Ten countries in 1975. It consists of senior
representatives of bank supervisory authorities and central banks from Belgium, Canada, France,
Germany, Italy, Japan, Luxembourg, Netherlands, Sweden, Switzerland, United Kingdom and the United
States. It usually meets at the Bank for International Settlements in Basle, where its permanent Secretariat
is issuing this framework for the evaluation of internal
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and off-site supervisory techniques and the degree to which external auditors are also used in
the supervisory function, all members of the Basle Committee agree that the principles set
out in this paper should be used in evaluating a bank’s internal control system.
4. The Basle Committee is distributing this paper to supervisory authorities
worldwide in the belief that the principles presented will provide a useful framework for the
effective supervision of internal control systems. More generally, the Committee wishes to
emphasise that sound internal controls are essential to the prudent operation of banks and to
promoting stability in the financial system as a whole. While the Committee recognises that
not all institutions may have implemented all aspects of this framework, banks are working
5. The guidance previously issued by the Basle Committee typically included
discussions of internal controls affecting specific areas of bank activities, such as interest rate
risk, and trading and derivatives activities. In contrast, this guidance presents a framework
that the Basle Committee encourages supervisors to use in evaluating the internal controls
over all on- and off-balance sheet activities of banks and consolidated banking organisations.
The guidance does not focus on specific areas or activities within a banking organisation. The
exact application depends on the nature, complexity and risks of the bank’s activities.
6. The Committee provides background information is section I, sets out the
objectives and role of an internal control framework in Section II, and stipulates in sections III
and IV of the paper thirteen principles for banking supervisory authorities to apply in
assessing banks’ internal control systems. In addition, Appendix I lists reference materials
and Appendix II provides supervisory lessons learned from past internal control failures.
Principles for the Assessment of Internal Control Systems
Management oversight and the control culture
The board of directors should have responsibility for approving and periodically
reviewing the overall business strategies and significant policies of the bank;
understanding the major risks run by the bank, setting acceptable levels for these
risks and ensuring that senior management takes the steps necessary to identify,
measure, monitor and control these risks; approving the organisational structure;
and ensuring that senior management is monitoring the effectiveness of the
internal control system. The board of directors is ultimately responsible for
ensuring that an adequate and effective system of internal controls is established
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Senior management should have responsibility for implementing strategies and
policies approved by the board; developing processes that identify, measure,
monitor and control risks incurred by the bank; maintaining an organisational
structure that clearly assigns responsibility, authority and reporting relationships;
ensuring that delegated responsibilities are effectively carried out; setting
appropriate internal control policies; and monitoring the adequacy and
effectiveness of the internal control system.
The board of directors and senior management are responsible for promoting high
ethical and integrity standards, and for establishing a culture within the
organisation that emphasises and demonstrates to all levels of personnel the
importance of internal controls. All personnel at a banking organisation need to
understand their role in the internal controls process and be fully engaged in the
An effective internal control system requires that the material risks that could
adversely affect the achievement of the bank’s goals are being recognised and
continually assessed. This assessment should cover all risks facing the bank and
the consolidated banking organisation (that is, credit risk, country and transfer
risk, market risk, interest rate risk, liquidity risk, operational risk, legal risk and
reputational risk). Internal controls may need to be revised to appropriately
address any new or previously uncontrolled risks.
Control Activities and Segregation of Duties
Control activities should be an integral part of the daily activities of a bank. An
effective internal control system requires that an appropriate control structure is
set up, with control activities defined at every business level. These should include:
top level reviews; appropriate activity controls for different departments or
divisions; physical controls; checking for compliance with exposure limits and
follow-up on non-compliance; a system of approvals and authorisations; and, a
system of verification and reconciliation.
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An effective internal control system requires that there is appropriate segregation
of duties and that personnel are not assigned conflicting responsibilities. Areas of
potential conflicts of interest should be identified, minimised,
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