Modernizing Governance, Risk and Compliance: Resilience in a Disrupted World

Why Enterprises Are Racing to Reinvent GRC

The banking sector is undergoing a significant shift in its approach to governance, risk, and compliance (GRC), driven by escalating cyber threats, evolving regulations, and the growing demand for operational resilience. High-profile disruptions such as the CrowdStrike outage, which caused billions in losses and widespread paralysis—have underscored the urgent need for robust, technology-enabled GRC frameworks. Similarly, in the banking industry, several incidents have occurred due to technology outages impacting retail banking operations, such as online banking, as well as outages at third-party data centers that disrupted customer payment services.

As regulatory bodies like the RBI (India), OCC (USA), and FCA (UK) tighten compliance expectations, and frameworks such as NIST, COSO, and Basel continue to evolve, banks are compelled to modernize their GRC strategies to stay competitive and secure. The convergence of AI, machine learning, and advanced analytics is transforming how the banks assess, predict, and respond to operational risks.

Bridging the Gap: From Legacy Models to Modern GRC

Traditional GRC models are no longer adequate for today’s complex enterprise landscape. Banks must navigate intricate third- and fourth-party dependencies that introduce hidden risks and require continuous oversight. Fragmented data ecosystems further hinder timely and accurate risk assessments. Additionally, the convergence of regulatory requirements demands a harmonized approach across multiple compliance frameworks, challenging the effectiveness of legacy systems.

To address these challenges, a modern GRC approach must integrate AI-driven simulations, automated assessments, and real-time data collection to predict and mitigate risks across the technology value chain. Tools like AgenticAI enable dynamic questionnaires and risk profiling, while certified technology specialists ensure accuracy and compliance.

Strategic Blueprint for Scalable Resilience in Banking

To thrive in an era of constant disruption, banks must evolve beyond compliance and embed resilience into the core of their operations and customer service. This requires aligning risk appetite with operational capabilities and adopting scalable, business-centric strategies.

Key AI levers that can be implemented for efficiency and effectiveness include:

Enhanced Inherent Risk Visibility and Control

• Real-Time Risk Tracking: Maintain dynamic risk rating, continuously updated risk registers to swiftly respond to emerging threats. Agents can play a vital role in addressing real-time aspects and ensuring accurate risk assessments.
• Risk and Control Process Mapping: Conduct end-to-end visibility exercises across people, technology, and operations to identify vulnerabilities and optimize controls. Banks are increasingly utilizing agents for automated mapping exercises.
• Self-Assessment & Documentation: Routinely evaluate the effectiveness of controls and maintain a comprehensive risk and control register to reflect evolving risk profiles. Agents can augment this process by automatically sending assessments to assessors on a regular basis.

AI-Driven Automation

• Vendor Risk Assessments: Use AI to evaluate third- and fourth-party vendors across financial and non-financial metrics, reducing manual effort and improving accuracy.
• Automated Risk Reviews: Leverage AI to accelerate assessments and free up teams for high-value strategic work.

Impact Tolerance & Prioritization

• Defining Tolerance Thresholds: Establish clear limits for business disruptions (e.g., online banking recovery within 2 hours) to guide resource allocation and recovery planning.
• Priority Focus: Concentrate efforts on the most critical products and services to ensure resilience investments deliver maximum value. Agents can help identify priorities for assessing potential impacts on business operations, enabling staff to proactively manage expected losses or high residual risks.

Scenario Testing & Benchmarking

• Scenario-Based Stress Testing: Identify known and unknown vulnerabilities, assess control gaps, and validate contingency plans. Agents can help generate contextualized “what-if” scenarios based on the bank’s business and strategic objectives.
• Industry Benchmarking: Securely share non-personal data to compare practices with peers, identify best practices, and elevate sector-wide resilience. Agents can help draw industry external data and historical lessons to create an outside-in view.

Unified Governance & Strategic Alignment

• Integrated Policies: Consolidate business continuity, cybersecurity, operational risk, and third-party management policies to eliminate silos and streamline compliance.
• Governance Alignment: Engage the Board and senior leadership in embedding resilience frameworks and continuously upgrading the operating model.
• Strategic Fit: Ensure all resilience initiatives align with broader business goals, integrating people, processes, and technology from the outset.

RCSA: A Critical Enabler in Modern GRC Frameworks

Embedding a modern Risk and Control Self-Assessment (RCSA) tool into the GRC framework is essential for identifying and assessing inherent risks. Leveraging accurate historical data, the tool supports precise risk evaluation and ensures residual risk remains aligned with the organization’s appetite.

Our operating model outlines the key dimensions of RCSA, supported by a structured approach, clear ownership, and automation to drive efficiency. The tool helps link risks to products and services, assess control effectiveness, and optimize investment in mitigation strategies. While automation covers most of the process, select manual checks remain critical for high-impact areas.

Establishing foundational pillars—people, process, and technology—in alignment with business goals ensures the RCSA delivers strategic value. Incorporating external market and technology trends keeps the framework current and enhances the risk and control library for future-readiness.

Case in Point: Building Resilience Through Risk-Driven Transformation

A leading UK retail bank embarked on a large-scale IT transformation to design, build, and migrate to a new core banking platform. However, the migration triggered severe service disruptions impacting digital and phone banking, branch systems, and card transactions, resulting in over 225,000 customer complaints and significant regulatory penalties.

Wipro partnered with the bank to turn this challenge into an opportunity. We implemented a robust GRC framework, including advanced risk assessments, scenario analysis, and control testing across IT and operations. Additionally, we strengthened contingency planning and business continuity controls. These measures reduced operational risk, enhanced resilience, restored customer trust, and a future-ready platform enabling seamless migrations and regulatory compliance.

Futureproofing GRC Starts Today

In an era defined by volatility and digital interdependence, the banking sector must dismantle outdated frameworks and embrace intelligent, integrated, and resilient GRC models that can withstand disruption and drive sustained growth.

CxOs must champion a comprehensive GRC modernization agenda—beginning with a clear-eyed assessment of current capabilities, followed by targeted investments in scalable technologies and enterprise-wide alignment. This is the moment to engage the board, empower cross-functional teams, and collaborate with trusted partners to build a GRC ecosystem that is proactive, predictive, and purpose-built for the future.

By embedding tools like RCSA and aligning resilience initiatives with strategic objectives, banks can streamline controls, accurately assess risks, and position themselves for long-term success.

The cost of inaction is too high. The opportunity to lead is here.

About the Authors

Venkatesh Balasubramaniam
CAMS, CFCS, DMTS – Senior Principal Member, Consulting Partner, Head – BFSI Consulting, Americas Hub, Global Head – Financial Crime and GRC Practice

Venkatesh is an experienced BFSI consulting leader with more than 28 years of corporate experience. He specializes in banking regulatory compliance and brings extensive experience in technology consulting and transformation across areas such as fraud, AML, KYC/CDD, sanctions, GRC, and compliance regulatory reporting.

He is a Senior Principal Member in Wipro’s Distinguished Members of Technical Staff (DMTS), focused on building AI/GenAI/Agentic AI solutions to address customers’ business and technology challenges.

Joydeep Sarkar
Senior Architect – Blockchain, AI/ML

Joydeep is a senior architect with over two decades of experience in distributed and decentralized computing, as well as artificial intelligence. He is also a Principal in Wipro’s Distinguished Members of Technical Service, focused on building AI/ GenAI engineering solutions.

Dr. Gopichand Agnihotram
Director, Wipro Innovation Network (WIN)

Dr. Gopichand brings over 19 years of experience in artificial intelligence and machine learning to his role. He also serves as a Principal Member of the Distinguished Technical Staff at Wipro. A prolific innovator, he holds more than 40 patents and has authored over 50 publications in esteemed platforms such as Springer and IEEE. His impactful contributions to the fields of AI and ML underscore his deep expertise and unwavering commitment to advancing the frontiers of technology.