JPMorgan Chase (JPMC) is committed to providing high quality and resilient services to our customers and clients. This is done through a rigorous control program committed to meeting legal and regulatory obligations in each of the jurisdictions where we do business.
Our Global Business Resiliency program is designed to provide an integrated firmwide resiliency program aligned to our business strategy and principles, as well as the requirements of our customers and clients globally. We do this by:
- Providing continuity of client and customer services while protecting the firm’s employees and assets;
- Engaging senior management on key aspects of the program, including determining the resiliency risk appetite, strategy, leadership and program oversight;
- Proactively managing resiliency risks to incorporate appropriate mitigations and controls;
- Developing and maintaining resiliency plans based on impact analysis and criticality; and
- Helping employees understand their role in recovery scenarios and undertake validation tests and exercises across critical functions and locations.
The information below provides details about the key aspects of our program.
Regulation and Compliance:
Our resiliency policy and standards establish requirements for resiliency planning, response and recovery across the firm. The program is:
- Managed by a firmwide resiliency Steering Committee, comprised of senior management from each line of business as well as relevant JPMC corporate functions;
- Reviewed and approved by the Audit Committee of the Board of Directors of JPMC on an annual basis;
- Subject to risk-based examinations by JPMC internal auditors; and
- Subject to regular inspection by regulatory authorities, including the US Office of The Comptroller of the Currency (OCC), The Federal Reserve Board (FRB), The UK Financial Conduct Authority (FCA) and Prudential Regulation Authority (PRA), the Monetary Authority of Singapore (MAS) and other national regulatory authorities.
Crisis Management Processes:
A robust crisis management process exists to ensure efficient, effective and timely response to incidents of varying severity and types.
- A firm-wide notification tool is used internally to communicate in crises;
- Escalation processes are in place and are routinely tested; and
- Post event reviews are undertaken to ensure event management procedures and resiliency capabilities are continually enhanced.
Managers throughout the firm develop and maintain resiliency plans as part of the program.
- Annual impact analyses are performed to determine or confirm the relative criticality of processes;
- Lines of business maintain resiliency plans, based on their business impact analysis and risk assessments, addressing business, staff, operations and technology components, and critical services provided by third parties;
- Plans address high-level absenteeism events, including pandemic and severe weather;
- Quality reviews and audit assessments are undertaken and where appropriate corrective measures implemented; and
- Senior management reviews and approves resiliency plans annually.
Testing and Exercising:
The firm employs a comprehensive testing approach to regularly validate the effectiveness of the resiliency program under different impact scenarios:
- Tests include simulation exercises and physical tests of recovery strategies;
- Test results are communicated to the firm’s senior management across business functions, as appropriate; and
- The firm regularly participates in market-wide and industry sponsored exercises.
JPMC has over 1,000 staff dedicated to cyber operations and operates three 24/7 cyber operational centers around the globe. Cyber staff work to identify areas of weakness as well as proactively respond to cyber threats and attacks as they occur.