Advisory and implementation to comply with Superintendency of Banks regulations
Implementation of policies, procedures and internal controls aligned to SBP Agreements. Inspection preparation, observation remediation, banking process documentation. Deep knowledge of Panamanian local regulation.
Complying with Superintendency of Banks of Panama regulation is non-negotiable obligation but resource-intensive. CFOs and COOs of financial institutions face constant challenge: implement compliance without stopping operations, without excessive bureaucracy, and demonstrating to SBP that controls are effective (not just documents in drawer). Alternative helps financial institutions comply with SBP regulation efficiently: we design and implement pragmatic compliance systems, prepare for inspections, remediate observations, and document processes so that internal audit, external audit and SBP accept without objections.
Regulatory compliance services for financial institutions
Policy and Procedure Design and Implementation
We develop corporate policies and operational procedures aligned to specific SBP Agreements: corporate governance, operational risk management, internal controls, compliance management, business continuity, information security.
- Corporate policy manual
- Operational procedures by critical process
- Risk and control matrices
- Implementation action plans
Banking Process Documentation
Mapping and formal documentation of core banking processes: credit approval, account opening, treasury, reconciliations, regulatory reporting, AML/CFT. Documentation with level of detail SBP requires: narratives, flow diagrams, RACI matrices, implemented controls.
- Process narratives
- Flow diagrams
- RACI matrices
- Control documentation
SBP Inspection Preparation
Internal pre-audits that simulate SBP inspection. We identify gaps that inspectors would find. We prepare documentary evidence that SBP requires. We train team on how to respond to inspector requirements.
- Internal pre-audit
- Gap identification
- Evidence preparation
- Team training
Regulatory Observation Remediation
Analysis of observations issued by SBP. Remediation plan design with specific corrective actions. Control implementation to close identified gaps. Evidence preparation for observation closure.
- Observation analysis
- Remediation plan
- Control implementation
- Closure evidence
Internal Control Systems
Design and implementation of internal control frameworks aligned to COSO: control environment, risk assessment, control activities, information and communication, monitoring. We develop key control matrix, effectiveness testing, deficiency remediation.
- Internal control framework
- Key control matrix
- Effectiveness testing
- Deficiency remediation
What the regulation requires, specifically
Most compliance projects stall for the same reason: the regulation is treated as a list of documents to deliver rather than a set of capabilities you must be able to demonstrate in operation. The difference shows at the first inspection.
Agreement 011-2018
Operational risk · September 11, 2018
It establishes that operational risk management must include identification, measurement, mitigation, monitoring and control. The point that generates the most findings is not identification but monitoring: you must be able to demonstrate that mitigation actions were closed within the defined timeframes, with evidence rather than generic minutes.
Agreement 005-2011
Corporate governance · September 20, 2011
It updates the corporate governance provisions. In operational terms it defines who answers for what: committee composition, reporting lines and board responsibilities. An internal control framework without that structure behind it does not survive the first review, however well drafted.
How we approach it
Order matters. Documenting before understanding which controls exist produces manuals nobody recognizes as their own and that do not survive a review.
Gap assessment
We compare what the institution does today against what the regulatory framework requires you to be able to demonstrate. The output is not a list of missing documents but a control map: which ones exist and operate, which exist on paper but nobody executes, and which do not exist.
Prioritization by criticality
You do not document everything at once. Work is ordered by two criteria: what an inspector reviews first and where a failure hits the customer or the balance sheet. That order is what allows showing real progress in the first months instead of an open front everywhere.
Governance and role design
Before writing procedures we define who decides, who executes and who reviews. Committees, reporting lines and process owners. Without this layer, the documentation that follows becomes a drafting exercise with no effect on operations.
Documentation at evidence level
Narratives, flow diagrams, RACI matrices and risk and control matrices. The quality criterion is not length but whether a third party can follow the process and verify that the control operated, with records that genuinely exist.
Internal pre-audit
We simulate the approach of an inspection over the already documented processes. The goal is to find the findings before the inspector does, while there is still room to correct them without a deadline overhead.
Closure and handover
Preparation of closure evidence and training for the team on how to answer a request: what to show, where it is and what should not be improvised. The system has to keep running without us.
Frequently asked questions
With a gap assessment: we compare what the institution does today against what the regulatory framework requires to be documented, and we prioritize by criticality. You do not document everything at once. You start with the processes an inspector reviews first and with those where a failure has direct impact on the customer or the balance sheet.
Agreement 011-2018 establishes that operational risk management must include identification, measurement, mitigation, monitoring and control. In practice that means a manual is not enough: you must be able to demonstrate the full cycle with evidence, including follow-up showing that mitigation actions are closed within the defined timeframes.
Both, and the second is of little use without the first. We run an internal pre-audit that simulates the approach of an inspection, identify the likely findings and prepare the evidence. We also work with the team on the part that is in no manual: how to answer a request, what to show and what not to improvise.
Agreement 005-2011 updates the corporate governance provisions, and in practice it defines who answers for what. An internal control framework without clear owners and without reporting to the board falls apart at the first review. That is why the design of roles, committees and reporting lines comes before detailed documentation, not after.
Yes, and it is one of the most frequent engagements. We analyze the observation to understand which control failed, not just which document is missing. From there we build the remediation plan with concrete actions, owners and dates, implement the controls and leave the closure evidence prepared.
Does your institution need SBP compliance support?
Free 30-minute evaluation. We review your current compliance situation and recommend priority actions.