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COO Magazine Q1 2025

Managing Business Risk

Maurice Evlyn-Bufton
CEO
Armstrong Wolfe

Chris Rigg
AW Alliance Partner
Global Economics Group

Determining responsibilities between the business, risk management and compliance

Time for Resolution: 10 Years of Debate Between the 1st and 2nd Lines of Defences.

2025 marks the tenth anniversary of Armstrong Wolfe’s establishment of the Chief Control Officer forum. A cornerstone initiative of the International COO Community (iCOOC), this forum has served as the central hub for debate, collaboration, and thought leadership on 1st line business risk and controls across Corporate and Investment Banking.

Over the past decade, the Markets Chief Control Officer community has met quarterly in London and New York, with virtual roundtables extending across APAC. The community now boasts representation from over 30 banks, spanning major U.S., Canadian, British, French, German, Spanish, Japanese, and Australian institutions.

In Q2 2024, this well-established forum expanded to include a cross-divisional business risk executive community, and with 23 banks convening in hybrid, member-hosted meetings. Notably, many participants in this broader group were foundational voices in the Markets community between 2015 and 2020, and with promotion and a broadening of their responsibilities continue to participate in Armstrong Wolfe’s activities.

Throughout this decade of dialogue, one question has remained unresolved and central to the debate:

How do we clearly define the roles and responsibilities of the 1st and 2nd lines of defence?

The question persists, often accompanied by a familiar tension:

  • The 1st line asserts insufficient headcount to meet its accountability for business risk.
  • The 2nd line faces scrutiny over its inconsistent mandate and seemingly smoother path to securing resources.

This imbalance and lack of consistency in the operating model became the focal point of the Q4 COO and Control Officer roundtable debate, held at The Yale Club.

50 executives from 22 banks participated, representing equal voices from the 1st line (COOs and Chief Control Officers) and the 2nd line (Compliance and Operational Risk).

Divided across five tables of ten, each group was led by two moderators, one from the 1st line and one from the 2nd line, supported by Armstrong Wolfe Industry Advisors and alumni, who recorded minutes and contributed to this paper.

    The collective was given a bold challenge: “Resolve a ten-year issue in 60 minutes.”

    Moderators guided the discussions, and upon conclusion, each table presented its summary findings to the group What emerged was remarkable: a clear commonality of thought and agreement on the measures needed to deliver the efficient, effective framework sought by both the industry and its regulators.

    It is hoped this paper and this milestone can mark a turning point in resolving a decade-long debate, highlighting the collective will of business risk leadership across 1st and 2nd line to drive meaningful and lasting change.

    If you are not a member of iCOOC and our affiliate networks and would like to read this Industry Whitepaper, please contact in the first instance Maurice Evlyn-Bufton CEO, Armstrong Wolfe

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