Fear is not a good advisor
Risk management is a reflection of the issues that affect our society. Because wherever new developments emerge, risks arise. Nowhere is this more evident than in the geopolitical developments that are currently keeping us on tenterhooks. Two years ago, this was still a topic for thought leaders. Today, it is the dominant risk with a direct impact on the economy and society.


Technical contributions
The big picture: Controlling the NFR Puzzle
By Sonia Dribek-Pfleger, Dr. Lorenz Schendel
While the individual frameworks of Non-Financial-Risks (NFR) are becoming more detailed and comprehensive with increasing regulatory requirements (e.g. DORA), current challenges (pandemic, cyber, AI, geopolitical crises) and increasing team size and decentralisation of risk management activities, the overall view of non-financial risks is increasingly suffering. In this article, we present both pragmatic approaches for initial steps and a long-term target picture for the holistic management of non-financial risks, with the aim of creating consistency between the various NFR data, making the NFR risk profile transparent and achieving efficient risk management by focusing on the material risks.
AI Armor: Protecting Banks with Advanced Connected Analytics
By Dominik Käfer, Dr. Lue Wu
In today’s global, interconnected environment, economic crime risk remains a pervasive challenge. Governments around the world are signaling their rising expectations that compliance programs become more sophisticated. The way financial institutions defend themselves against risks like fraud, money laundering, terrorist financing and cyberattacks has changed significantly as a result of the use of artificial intelligence (AI), particularly through advanced connected analytics. This article summarizes how AI is boosting banking security (and at the same time cost efficiency), showcasing a concrete use case and analyzing the industry’s ramifications.
Quantifying natural risk – challenging, but possible
By Markus Quick, KPMG AG WPG Frankfurt, Dr. Holger Spielberg, Armina Schädle, Tania Jötten
Five years ago, banks were faced with the challenge of measuring climate risks and integrating them into their risk management. Now, biodiversity loss is gaining attention and is joining climate risks on the political and regulatory agenda. Experience from the climate sector provides a valuable basis for all risk management processes. However, biodiversity risks are significantly more complex and extensive, which leads to challenges right from the definition and identification stage. Many institutions have started to assess their portfolios via established data providers such as Exploring Natural Capital Opportunities, Risks and Exposure (ENCORE).
Quo vadis European Capital Markets Union – challenges and realizations
By Eddy Henning, Prof. Dr. Michael Torben Menk, Dr. Joachim von Schorlemer
The majority of political and business representatives are aware that a European economic and monetary area will only have a competitive future if, around ten years after the European Commission’s action plan – the Green Paper on the creation of a Capital Markets Union – it finally succeeds in transforming the currently fragmented and mostly underdeveloped national capital markets into an integrated single European capital market. This article firstly highlights the need for investment in transformation, which is a fundamental and lasting challenge for Europe. In addition, the authors see the revitalization and deregulation of the European securitization market.
Resilience, goal achievement and sustainability in the age of transformation
By Prof. Dr. Josef Scherer
The revised guidelines on internal governance of the European Banking Authority (EBA) and the guidelines on the assessment of the suitability of members of the management body and key function holders of the EBA and the European Securities and Market Authority (ESMA) have been in force since December 31, 2021. When studying the guidelines, the need for modern governance adapted to the times of transformation becomes clear. The addressees also get a feeling for what is included in the area of governance and which regulatory requirements need to be met. There is no fundamental discussion of the concept and legal scope of governance as a whole in the guidelines, meaning that there is still a need for further discussion, qualification and action in this respect.
Banking study: Data blind flight looms without a strategy
By Björn Berg, Dr. Stefan Hirschmann
When it comes to collecting and storing data, the financial industry is one of the driving forces. And for good reason, because the smart use of data will be the key to success or failure in the future. But why are banks and capital management companies still finding it so difficult to generate added value from the existing mountain of data? A recent study by VÖB-Service and the management consultancy Cofinpro provides the answers. The financial sector of all sectors – a first mover in the IT world – has so far held back when it comes to tapping into the data economy for business purposes. In a survey of experts, we investigated the reasons and asked: Why are financial institutions not exploiting their potential?
The banking crisis of the last 36 months
By Prof. Dr. Markus Rudolf
With the crisis at the American Silicon Valley Bank in 2023, the decline of the Swiss Credit Suisse in 2024 and the start of the takeover of Commerzbank by UniCredit, 10 years of relative stability for international banks appear to have come to an end. All three cases have their origins in the banking and financial crisis of 2008 to 2012 and ultimately in the collapse of Lehman Brothers. The Lehman Brothers case in 2008 plunged numerous banks into crisis, initially in Iceland and Ireland and later also in the UK and on the European continent. Entire countries and the euro had to brace themselves against their own demise by rescuing entire banking systems.
Regulatory Ambiguity and Credit Risk Requirements for Implementing EU Final Basel III Rules
By Joo-Yung Lee, Jan Schimmel
Last year we discussed the changes to the standardised approach (SA) for calculating risk-weighted assets (RWAs) for credit risk and its implementation challenges. All banks, including banks using the Internal Ratings Based (IRB) Approach will have to calculate the SA either as their main capital calculation or, in the case of ‘IRB banks’, in order to apply the output floor. The rules are now final in the EU with a go live date of 1 January 2025 with full implementation by end-2032 following a phase-in period. Several regulatory interpretation questions have emerged as banks are implementing these changes, some of them driven by larger banks who are focusing on the standardized approach more than they have in the past.
ICT risk management under DORA – integration into ICAAP and ILAAP
By Prof. Dr. Andreas Igl
The introduction of the Digital Operational Resilience Act (DORA) from January 17, 2025 takes the importance of robust ICT risk management to a new level. As part of operational risk, ICT risks are becoming particularly relevant, as their impact not only directly influences operational stability, but also the capital and liquidity planning of banks. Operational risks, including ICT risks, must therefore be systematically identified, assessed and managed as part of the Internal Capital Adequacy Assessment Process (ICAAP) and Internal Liquidity Adequacy Assessment Process (ILAAP). The article highlights approaches for approximating and quantifying ICT risks.
Information register: The underestimated DORA hurdle
By Stefan Wendt
One of the key instruments required by the Digital Operational Resilience Act (DORA) is an effective information register. It is intended to ensure that financial service providers maintain an overview of existing dependencies on third party providers. What seems comparatively trivial is actually one of the higher hurdles on the road to compliance, which must be achieved by January 2025. There are tools for this – but their quality has yet to be proven. DORA focuses on dealing appropriately with the financial sector’s increasing dependence on third-party providers. The aim is to maintain operational stability in the event of a serious disruption.
Consistency of interest rate risk management and IFRS hedge accounting through the future DRM model?
By Volker Liermann, Oliver Wulle
The DRM model as the future IFRS portfolio hedge accounting model is intended to resolve the long-standing tension between interest rate risk management at portfolio level and its presentation in the IFRS financial statements and overcome the weaknesses of the still relevant IAS 39 Portfolio Fair Value Hedge. Some risk managers in particular are demanding for the risk management view to be fully incorporated into the IFRS financial statements. The question therefore arises as to the extent to which a complete risk management view is possible or sensible in IFRS financial statements and how the risk management view can be adapted as far as possible in the DRM model.
Risk modeling for a stable financial system. A utopia.
By Dr. Wilfried Paus
At the wake of the EU implementation of Basel IV it appears that the modernization of financial risk measurement, which was initiated by the 2008 Basel II reforms, has been largely dismantled. Even more so, there remain voices that go far beyond the reduction of excessive variability in the capital requirements envisaged by the framework underlying the EU CRR3 legislation [BCBS 2017]. This article is intended as a plea to revive precise risk measurement and re-think risk management processes for effectiveness rather than letting the sector slide back further into the intellectual middle ages.
In October 2024, I was invited to a book event at Frankfurt’s Goethe-University organized by the Leibniz Institute for Financial Research SAFE.
Perverse instantiation and reward exploitation in AI applications
By Dr. Dimitrios Geromichalos, FRM
The increasing use of ever more advanced artificial intelligence (AI) methods is leading to a fundamental change in the financial sector. The main drivers for this are the many advantages of these methods, which enable complex classifications, precise cluster and outlier analyses and in-depth text analyses, among other things, and contribute significantly to optimized decision-making and increased efficiency in numerous processes. However, these advantages are also associated with considerable challenges. Data inaccuracies and bias can distort results, while overfitting impairs the reliability of the models. In addition, more powerful models are usually “black boxes” whose results are often not comprehensible and explainable, or only for individual examples.
LLM and its increasing relevance in cyber security
By Frank Romeike
In recent years, large language models (LLMs) have made significant advances in their performance and in many areas are now achieving capabilities beyond those of the human brain. These models, including GPT-4, have the potential to be used in both value-added and malicious contexts. Academic research and practitioners have begun to investigate the potential of LLM agents to exploit cybersecurity vulnerabilities. However, previous studies were limited to simple vulnerabilities. The current paper “LLM Agents can Autonomously Exploit One-Day Vulnerabilities” investigates whether LLM agents can autonomously exploit real, complex vulnerabilities, in particular so-called one-day vulnerabilities, i.e. vulnerabilities that are known but not yet patched.
IRO and ESRS – control through risk governance
By Univ.-Prof. Dr. Arnd Wiedemann, Chair of Finance and Bank Management, University of Siegen, Yanik Bröhl, Chair of Finance and Bank Management, University of Siegen
IRO stands for Impacts, Risks and Opportunities.
This triad is the central basis of the European Sustainability Reporting Standards (ESRS).
In order to be able to report on the success of their sustainability activities, companies must have implemented a process for identifying, measuring and managing their impacts, opportunities and risks.
This triad also forms the basis of the materiality analysis and enables a comprehensive view of a company’s sustainability activities and the associated consequences.
Effective risk governance plays a central role here, as it links the IRO triad required for external reporting with internal corporate management.

Position papers
Geopolitical risks
By Dr. Til Bünder, Gerold Grasshoff, Emilia Zimermann
The economic structure around the globe is becoming increasingly complex and trade conflicts and military tensions are posing various risks for national economies, companies and financial institutions. In such a situation of uncertainty, proactive risk management is more important than ever for banks. The current FIRM position paper Banks Navigating Global Crises: Analysis of Geopolitical Risks and their Impact on the Financial Sector summarizes what needs to be considered, how scenarios are defined, quantified and appropriate mitigation measures derived.
The authors Gerold Grasshoff, Dr. Til Bünder and Emilia Zimermann look at the potential impact of recent developments in China, the Middle East and the political change of course in the USA. The analysis focuses on German and European banks: how do geopolitical risks affect their credit, market, liquidity, business, sanctions and cyber risks? The position paper offers comprehensive guidelines for dealing with geopolitical challenges in the financial sector.
Artificial intelligence
By Dr. Jochen Papenbrock, Dr. Sebastian Fritz-Morgenthal, Philipp Adamidis
In the position paper "Challenges and opportunities for model risk management", the authors describe why the use of artificial intelligence (AI) in banks promises a variety of benefits - from increasing efficiency to improving decision-making. At the same time, the increased use of AI models brings with it new challenges, particularly in the area of model risk management.
Strategies pursued to date require a fundamental overhaul. The position paper examines the regulatory requirements and rules of the European Banking Authority (EBA), the European Central Bank (ECB), the German Federal Financial Supervisory Authority (BaFin) and the EU AI Act. It also shows how the expanded use of AI affects model risk and the challenges and, in particular, opportunities this presents for banks' model risk management.
ESG – Climate risks
By Dr. Til Bünder, Nicholas Martin
In the current FIRM Round Table ESG position paper, the authors examine the climate policy measures of the European Union (EU) and the United States (US) in terms of their impact on economic performance.
The authors Dr. Til Bünder and Nicholas Martin explain how the significantly more ambitious regulations in the EU will affect various economic levels, where opportunities will arise and what risks need to be considered. A comparison of the EU and US climate and energy policies shows that the US is becoming more attractive due to its direct and simple approach to promoting green investments. The EU, on the other hand, is jeopardizing its leading position in the field of green innovation and investment due to its more complex regulation and the fragmentation of financing mechanisms. It is therefore crucial that the EU continues to develop its political framework conditions in such a way that climate targets are achieved and its economic competitiveness is secured at the same time.
Review of the year 2024

Banking Risk Round Table 2024
By Jan Jelovsek

Compliance Risk Round Table 2024
By Stephan Beitz, Olaf Brüggemann

Payments Round Table 2024
By Dr. Markus Ampenberger, Prof. Dr. Tobias Berg, Daniel Regending

Round Table AI 2024
By Dr. Jochen Papenbrock, Dr. Sebastian Fritz-Morgenthal

Round Table Cyber Risks 2024
By Tobias Synak, Daniel Naumilkat

Round Table ESG 2024
By Dr. Til Bünder
The FIRM Conferences 2024
Award for young researchers

Sasan Mansouri wins the FIRM Research Award 2024
Dr. Sasan Mansouri wins the FIRM Research Prize 2024 with his dissertation on the information behaviour of managers at analyst conferences. He shares the prize money of 30,000 euros with the chair of Prof. Dr. Mark Wahrenburg from Goethe University Frankfurt, who supervised Mansouri's work.
read moreFIRM Advisory Board | Annual Report 2024

Review of the year by the Advisory Board Chairwoman
A year ago, despite the war in Ukraine, supply chain problems and inflation, we were confident about the new year, both economically and politically. In the meantime, the outlook has darkened. Nobody is talking about a victory over Russia anymore. Does the West have a convincing concept? Do we need a new iron curtain to provide a credible security guarantee for the free part of Ukraine? Are we experiencing a déjà vu in Syria like after the fall of Gaddafi in Libya?
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