The Impact Team have experience with helping financial organisations who, while headquartered in North America, have operations within the European Union. These operations come under the regulatory oversight and governance of the ECB (European Central Bank) and one of the audit points that the ECB have and will investigate is the degree of control an organisation has in defining roles, attributing access, allocating roles to people and ongoing management of the entire access control lifecycle.
Failure to be able to demonstrate adequate management in this aspect of your operation may very well result in sanctions being applied and we continue to provide our clients with advice and guidance in preparation for, or the remediation of, findings arising from audit points on this topic.