Each of our subcustodians annually supplies our network management team with Comprehensive Annual Attestation and Business Continuity Procedure (BCP) documents. An assessment of the subcustodian and its responses is made every year to identify gaps either in the market procedures (in terms of risk) or in the subcustodians’ processes.

On-site due diligence

On-site due diligence is an integral part of the CRA - and in most cases the remote CRA culminates with an on-site due diligence visit. Physical network checks, conducted on an ongoing basis, are an important part of the CRA. Accordingly, as part of our CRA policy we visit all markets at least once every two years.

On-site due diligence includes collection of data covering all relevant areas of control and risk management, as well as supplying required supporting documentation, also allowing for on-site inspection and review. Additional meetings are held with the respective market participants from the central securities depository to the stock exchange, central bank and local regulators.

Learn more about network management:

• Network management overview
• Best of breed approach
• Subcustodian monitoring & performance review