Wilfried Poabout

SREP Recommendation Mission issued by the ECB for compliance with EBA/DORA requirements on outsourced activities.

- EBA/DORA contractual remediation - Analysis of legal contractual gaps and risks related to services (FCI) with legal, compliance, and business teams – Piloting contractual remediation with group clausiers (SLA, PUPA, GDPR, KPI, reversibility clause, conflicts of interest, incident management, etc.) - Risk analysis, contract compliance, risk qualification - Guarantee of operational performance and continuity of outsourced activities.

- Drafting exit strategies - Development of exit scenarios: re-internalization, subcontracting, or abandonment – Evaluation of service substitutability (simple, complex, or impossible) – Definition of operational arrangements: human and technical resources, data transfer and management (processing, deletion), penalty or sanction clauses.

- Manage the Compliance team, develop and update procedures, PA ROSA, Monitor FIA Funds (Private Equity), Order placement and execution, control report, Reporting (QLB & FRA RAC), complaint management and relationship with the AMF mediator), Fraud, Prospectus for funds and KID

- Carry out the 2024 PCCI for about fifty controls: Product governance, client onboarding, KYC, AML-CFT, MIF2, PRIIPS FATCA, EMIR (ensure the application of central clearing standards for OTC derivatives, their reporting to regulators, monitoring and measurement of operational and counterparty credit risks, - CCP and Trade Repository -, compliance with financial contracts…), Conflicts of interest, distributor/marketing relationships, Investment and divestment processes, Own funds management control, PUPA (incident management to be updated according to DORA, IT and crisis testing) & GDPR (Data Protection, Processing and Archiving & Cyber), Subscription, redemption and transfer of units, PSEE, Website, Asset valuation and NAV calculation, Regulatory own funds, sending information to unit holders, Incident management, etc.

- Implementation of the PUPA policy and data archiving, development of major risk scenarios

- Business Impact Analysis (incidents, malfunctions, and Third Parties, BIA, DIMA/RTO), risk assessment and drafting of the BCP, continuity solution, Incident Register, and crisis management.