Bank of Åland Plc
The Risk Office Corporate Unit is primarily
entrusted with protecting the Bank of Åland’s
assets, earnings and brand by providing a
framework for risk and credit management.
Its purpose is to maintain a healthy risk cul-
ture that corresponds to the Bank’s risk appe-
tite and risk-bearing ability.
The Risk Control department is responsi-
ble for independent oversight and reporting
of the Bank’s financial risks. The finan-
cial year was dominated by new regulatory
requirements, and this will continue during
. During Risk Control worked with
the implementation of a new internal defini-
tion of default and made a concerted effort,
together with outside consultants, to update
credit risk models to comply with the new
definition and demanding new regulations,
while improving them to even better reflect
risk in the Bank’s loan portfolios. The Finnish
Financial Supervisory Authority has not yet
approved the new models; this is expected
during .
During the financial year, Risk Con-
trol will continue with implementation of new
regulatory requirements, primarily the Basel
IV regulation. In addition, the department is
participating in efforts to develop tools for
identifying, measuring, monitoring and
reporting risks attributable to climate change.
Risk Control also works with the Bank’s sus-
tainability plan and strategy as they relate to
responsible lending. This work has two
aspects: both to preserve those portions of
the Bank’s lending that already have a posi-
tive impact on sustainable development and
to design its lending to ensure that it will have
a positive impact on selected targets that are
part of the United Nations sustainable devel-
opment goals.
Compliance is an independent depart-
ment that identifies and monitors the Bank’s
compliance risks and reports on these to the
Executive Team and the Board of Directors.
The department provides advisory services
and back-up to the Executive Team and the
Bank’s business operations on how to man-
age compliance risks in order to ensure that
banking operations can follow regulatory
requirements, focusing on the interests of
customers. During the department’s
priorities included monitoring and providing
back-up to banking operations by means of
regulator-mandated development work that
will reinforce the Bank’s efforts to combat
money laundering and financing of terrorism.
Compliance strengthened its team in the field
of investment services and was thus able to
provide clearer back-up for compliance in
the Bank’s financial investment business.
The department also monitored and pro-
posed measures related to how the Bank
should oversee and follow up outsourcing
arrangements.
During the department will continue
to prioritise monitoring of compliance in
financial investment services as well as imple-
mentation of new and coming sustainability
regulations, with a focus on customer protec-
tion. Developing and improving the Bank’s
efforts to prevent money laundering and
financing of terrorism are always high on the
agenda, and this will continue in .
Operational Risks & Security is an inde-
pendent department that provides advisory
services and back-up and sets standards for
operational risk management. Its main areas
of activity are information security, data pro-
tection, releases, continuity and emergency
planning, security, criminal security, risk anal-
ysis and reporting and the new product
approval (NPA) process. The department
focuses on increasing awareness of opera-
tional risks, monitoring compliance in the
field of liability and reporting operational risks
and incidents to the Executive Team and pub-
lic authorities. The financial year was
dominated by participation in project work,
research and acquisition of systems support
for the Bank’s records of processing activities
under the General Data Protection Regulation
(GDPR), improved cybersecurity, quality
assurance of risk analyses, planning and coor-
dination of the Bank’s participation in the
FATO national emergency preparedness
exercise as well as process development
related to the partly owned mortgage com-
pany Borgo.
During the financial year the depart-
ment will continue to focus on advisory ser-
vices, back-up, standard-setting, monitoring
and reporting of operational risks. Back-up
during implementation of systems support
for establishing the Bank’s registry of pro-
cessing, further development of the fraud
prevention process, quality assurance of the
release process, back-up for physical security,
evaluation of the Bank’s cyber-maturity as
well as further development of the Business
Impact Analysis (BIA) are examples of
planned activities. The department will con-
tinue to share its process development exper-
tise in connection with the Bank’s partly
owned mortgage company Borgo.
The Legal Affairs department is responsi-
ble for meeting the needs of the Bank and the
Group for legal expertise, since the Bank
operates as a credit institution and issuer of
securities. The department works continu-
ously to provide back-up for business areas as
well as corporate units in developing and
supplying products and services to the Bank’s
customers. During the department
worked on implementation of new regula-
tions, with an emphasis on sustainability-
related regulations, legal issues related to
the new mortgage company and the expan-
sion of existing business partnerships.
During the department will work with
operational changes related to the start-up
of the Borgo mortgage company partner-
ship and continued implementation of new
regulations again with a strong emphasis
on sustainability and legal issues related to
new and existing business partnerships.
The Credit Scoring department develops
and carries out credit analyses and oversight
in order to ensure good credit quality in the
Bank’s lending. Despite the coronavirus pan-
demic, the proportion of unsettled loans in
the lending portfolio remained at about the
same level as at the beginning of the year,
excluding some large exposures that are not
connected to the coronavirus. There is good
potential to keep the proportion of unsettled
loans at current levels, provided the econ-
omy remains stable and real estate and
share prices remain steady as the pandemic
begins to fade. The department actively
participates in deliveries related to the
mortgage partnership as well as deliveries
required by European Banking Authority
(EBA) guidelines on loan origination and
monitoring. The Credit Scoring department
will participate in loan-related sustainability
work in keeping with credit processes, regu-
latory requirements and the wishes of the
Bank’s lending business.
The Credit Processes department is
responsible for administering and developing
the Bank’s lending process and ensuring that
it fulfils internal and external regulations. The
year was dominated by the implementation
of new regulations such as the EBA guidelines
on loan origination and monitoring, which
went into effect in June, as well as developing
a home loan platform for the new jointly
owned mortgage company Borgo. A mile-
stone was reached when the new home loan
platform went into service during the fourth
quarter. During there will be a focus on
continued development of Borgo’s digital
home loan platform as well as ensuring sus-
tainable and scalable processes related to
new regulations. Credit Processes will also
participate, together with Risk Control and
Credit Scoring, in the implementation of
coming sustainability regulations.