A structured risk register keeps CIRO-driven obligations visible, measurable, and actionable across regions. Use it as a living artefact integrated with enterprise risk, audit, and resiliency programs.
Risk ID
Unique identifier aligned to enterprise taxonomy (e.g., REG-CIRO-001).
Risk Name / Title
Concise descriptor of the compliance exposure.
Risk Description
Clear narrative of causes, obligations, and potential consequences.
CIRO Rule / Obligation
Specific reference to IDPC, MFD, UMIR, or By-Law requirements.
Risk Category
Primary classification such as Operational, Legal, Reputational, Strategic, or Cybersecurity.
Date Identified
Formal logging date to anchor governance cadence.
Risk Owner
Accountable leader or function overseeing the risk.
Inherent Likelihood
Probability score prior to controls using agreed scale.
Inherent Impact
Severity assessment pre-controls considering penalties up to $10M, remediation cost, and brand harm.
Inherent Risk Rating
Combined scoring or heat-map placement to aid prioritization.
Existing Controls
Documented policies, monitoring, technology safeguards, and assurance activities.
Residual Likelihood
Probability after evaluating control effectiveness.
Residual Impact
Post-control severity outlook.
Residual Risk Rating
Current exposure guiding further treatment decisions.
Mitigation Actions / Treatment Plan
Planned initiatives to reduce, avoid, transfer, or accept the risk.
Action Owner
Responsible party delivering mitigation work.
Target Completion Date
Deadline for mitigation milestones.
Status
Progress indicator such as Open, In Progress, Closed, or Overdue.
Review Date / Next Review Date
Most recent assessment and scheduled follow-up.
Escalation Level
Committee or executive trigger when thresholds are exceeded.
Notes / Comments
Context, links to evidence, incident history, or related risks.
Global Impact Consideration
Assessment of cross-border dependencies, data residency, or international scrutiny.
Inadequate Cybersecurity Measures
CIRO IDPC Rule 3900 and cybersecurity guidance notes.
Breakdown in cybersecurity controls leading to data breaches, trading disruption, or supervisory failure.
- Stand up a 24/7 security operations center and enhance monitoring analytics.
- Schedule red-team and penetration exercises with remediation governance.
- Expand encryption coverage for client data in transit and at rest across jurisdictions.
Inadequate AML / CTF Controls
CIRO Rules 2500 and 2600 plus FINTRAC reporting duties.
Weak client due diligence, transaction monitoring, or suspicious reporting enabling illicit flows.
- Deploy automated monitoring with anomaly detection tuned for cross-border transactions.
- Deepen enhanced due diligence for high-risk clients and geographies.
- Commission independent program reviews every two years to benchmark effectiveness.