The Boardroom Checklist for SC’s Guideline on Technology Risk Management Compliance

The Securities Commission Malaysia's (SC) framework for managing technology risk is a defining regulatory pillar for the nation's capital markets. The SC’s Guidelines on Technology Risk Management are not a technical manual for the IT department; they are a foundational component of corporate governance. The guidelines place direct accountability on the board of directors and senior management to ensure the security, reliability, and resilience of the technology that underpins market integrity and investor confidence.

For any capital market entity, navigating these requirements is a matter of strategic priority. To assist in this process, this guide distills the comprehensive policy into an essential checklist, focusing on the key duties and strategic questions that leadership must be able to answer.

The Core Principle: Board and Senior Management Accountability

The central tenet of the SC's guidelines is top-down accountability. The board must actively lead and oversee the institution's entire technology risk posture, while senior management is tasked with the development and implementation of the strategy. This ensures that technology risk is managed as a core business function.

A Leadership Checklist for Navigating the SC Guidelines

A board member or C-suite executive can use the following questions to drive conversations with their teams and assess their organization's compliance with the key pillars of the SC's TRM Framework.

Category	Assessment Questions
A. Governance & Oversight	Has our board formally approved a comprehensive Technology Risk Management (TRM) Framework and its associated policies? Has our board approved a clear risk appetite and tolerance statement that defines the level of technology risk we are willing to accept? Have we allocated adequate resources, including identifying a responsible person from senior management, to oversee technology risk day-to-day? Do our board members receive regular training and updates on new and emerging technology risks to ensure they can provide effective oversight? Do we have a formal technology audit plan, and are the auditors who perform it competent and experienced in this specific area?
B. Risk Management & Operations	Does our organization maintain a board-approved key technology risk register to facilitate ongoing monitoring and reporting? Do we have a robust and timely patch management process to remediate vulnerabilities discovered in our IT systems? Have we established and regularly tested a comprehensive IT Disaster Recovery Plan (IT DRP) to ensure we can restore critical systems within our defined recovery time objectives?
C. Third-Party & Cloud Governance	Do we perform comprehensive due diligence on all third-party service providers before engagement, assessing their financial stability, technical competency, and risk management capabilities? Have we performed a comprehensive risk assessment for the adoption of any cloud services, addressing key risks such as data location, access management, and vendor lock-in?
D. Cyber Security & Incident Response	Have we developed and implemented a formal Cyber Security Framework that includes strategies for identification, protection, detection, response, and recovery? Do we conduct regular penetration testing on our critical systems, at a minimum annually, performed by experienced and qualified professionals? Do we have a clear, documented process to immediately notify the SC upon detection of any technology incident, cyber incident, or near miss event?

Conclusion: The Value of Independent Assurance

This checklist provides a powerful tool for internal assessment and helps leadership focus on the core requirements of the SC's guidelines. However, true assurance often comes from independent validation. The SC's framework grants them the right to appoint an independent party to review an entity's compliance, underscoring the value of a proactive, independent review to confirm that your controls are not just designed correctly, but are also operating effectively.

Navigating these complexities requires a partner with deep expertise in both regulatory compliance and technical security. AKATI Sekurity's SC Technology Risk Management Independent Review Service provides the assurance that your frameworks, policies, and controls are robust, effective, and fully compliant. We help leadership teams and boards fulfill their governance duties with confidence.

Contact us to discuss how we can assist with your SC compliance needs.