Chapter Two: Internal Control in Banks

The Central Bank of Egypt has intensified its efforts to ensure that the internal control and risk management framework in banks is established and implemented effectively, by issuing this regulation to the Board of Directors of the Central Bank of Egypt in its session held on 19 August 2014, which approved the regulation on internal control and risk management in banks, with the following:

First: The purpose of this regulation is to ensure the continued availability of the necessary administrative and technical resources for the implementation of the provisions of this regulation, provided that banks have the ability to implement it within six months from the date of its publication.

Second: The scope of application of this regulation is limited to banks, and the existence of any exception to this regulation is prohibited.

Third: The provisions of this regulation shall apply to all banks, without prejudice to the obligation of banks to prepare a risk management policy (Risk Management Policy) that specifies the resources available to them, in addition to the first.

First: The General Framework

Introduction

The Central Bank of Egypt has made considerable efforts to establish an effective internal control and risk management framework, recognizing that it is an integral part of the bank's operations and a key factor in achieving its objectives. It has been observed that there are differences in the types and degrees of risks faced by banks, and that there is a need for a unified internal control and risk management framework that is not limited to internal audit and periodic reports, but requires the preparation of this regulation to support the internal control and risk management framework in Egyptian banks. It is also necessary to ensure that banks adopt an internal control and risk management framework that is appropriate to their nature and the existence of any exception to this regulation is prohibited. This regulation and the regulation issued by the Central Bank of Egypt on 23 August 2011 regarding the governance of banks and financial institutions.

Concept of Internal Control

Internal control is the process, implemented by the Board of Directors, senior management, and other personnel of the bank, designed to provide reasonable assurance regarding the achievement of the following objectives:

Objectives of Internal Control

• The effectiveness and efficiency of the bank's operations.
• The reliability of financial reporting.
• Compliance with applicable laws and regulations.

2 Elements of Internal Control

The internal control elements are considered the foundation for the achievement of the objectives, and are designed to provide reasonable assurance regarding the achievement of the bank's objectives, and include the following:

• The role of the Board of Directors and senior management in the bank.

• The establishment of an internal control structure (Internal Audit - Risk Management - Internal Control).

• The effectiveness of risk control.

• The effectiveness of information and communication systems in the bank.

• The effectiveness of internal control procedures related to the achievement of control and operational objectives.

• Continuous monitoring and evaluation of internal control and procedures, and the adoption of appropriate corrective measures for this purpose.

Responsibilities of the Board of Directors and Senior Management

It is clear that the Board of Directors plays a fundamental role in establishing internal control, as it is responsible for defining the framework for the existence of internal control, based on the separation of powers and the absence of conflict of interest, and providing continuous assurance regarding the bank's systems. The execution of this is delegated to the senior management of the bank, unless specific responsibilities are assigned to others.

1/5/1 Responsibilities of the Board of Directors

A- The Board of Directors is responsible for approving the bank's strategy and policies, including:

• The bank's strategic objectives, missions, and main activities.

• Defining the limits and authorities, and the acceptable risk limits for each type of risk.

• Defining the risk appetite.

• Defining the risk appetite level.

• Establishing procedures for identification, measurement, monitoring, and reporting of risks.

• Defining the activities and reports required to monitor the acceptable risks.

• Establishing contingency procedures for unexpected events.

B- The Board of Directors is responsible for reviewing and updating the bank's mission statement, including:

• The mission statement of the bank's management to ensure the proper distribution of powers and responsibilities among the members of the separation of powers.

• The senior management's awareness of the bank's mission statement (the bank and its subsidiaries), in order to identify the inherent and operational risks, and to implement appropriate controls.

• The need to ensure that internal controls are implemented for all activities.

C- The Board of Directors is responsible for reviewing the mission statement and the activities of the bank, including:

• The existence of an organizational structure and job descriptions that ensure the separation of powers and control, especially when new operational activities are introduced.

• The regular review of the bank's activities by the senior management, including the nature, characteristics, and activities of the activities, and the activities of the subsidiaries, based on a separate basis.

• The awareness of the nature and content of the bank's activities by the senior management, including the operational risks resulting from the bank's activities, and the operational risks resulting from the bank's activities, including the operational risks resulting from the bank's activities.

D- The Board of Directors is responsible for the continuous monitoring and evaluation of the effectiveness and establishment of the internal control and risk management procedures, and reporting to the senior management of the bank.

E- The Board of Directors is responsible for ensuring the independence of the internal audit function, including the establishment of an internal audit department that performs its duties in an independent manner, and the adoption of appropriate corrective measures for any deficiencies identified by the internal audit and senior management, in accordance with the provisions of the Internal Control and Risk Management Regulation.

F- The Board of Directors is responsible for ensuring that the new internal control and risk management policies and procedures are appropriate to the bank's activities and the senior management's awareness of the mission statement and the Board of Directors' study of the mission statement of the President/Chief Risk Officer, Internal Control, Legal, and Operational Departments.

G- The Board of Directors is responsible for ensuring the existence of an independent internal audit function that reports to the Board of Directors and the Audit Committee, and the independence of the internal audit function from the operational administrative departments of the mission statement.

1/5/2 Responsibilities of Senior Management

The senior management of the bank is responsible for:

• Implementing the strategy and procedures approved by the Board of Directors, and ensuring the effectiveness and efficiency of the processes in accordance with the approved policies.

• Adopting the necessary procedures and measures to identify, measure, monitor, and mitigate risks, and to limit their impact, in accordance with the Board of Directors' policies.

• Ensuring that the internal control system includes procedures to identify operational risks throughout the bank.

• Ensuring the availability of qualified resources for the expertise and technical skills required for the bank's activities and the continuous training and development of employees.

• Ensuring that the internal control procedures of the bank comply with the regulations issued by the Central Bank of Egypt and other regulatory authorities.

• Reporting to the Board of Directors any material changes to the mission statement in accordance with the bank's systems, and if there are fundamental changes to the nature and scope of the risks, and to report this to the senior management and the bank's systems.

Internal Control Culture

The Board of Directors and senior management of the bank are responsible for establishing and disseminating the necessary culture for the establishment of internal control and establishing a control environment for the bank's administrative employees, including the commitment of employees to the bank's systems, behavior, and ethics, in accordance with the senior management's awareness of the mission statement. It is necessary to ensure that the bank's systems, behavior, and ethics are not violated, and that the employees are aware of their role and responsibilities in the bank's systems, and that the employees are not exposed to risks that may cause losses to the bank.

Audit Committee

To achieve the objectives of the Audit Committee, the committee shall be formed in accordance with Article 27 of the Executive Bylaws of the Central Bank of Egypt and the Executive Bylaws issued pursuant to Law No. 88 of August 2003, and the regulations and regulations issued by the Central Bank of Egypt regarding the governance of banks.

The committee is responsible for the effectiveness of internal control in the bank, and its role is to report to the Board of Directors regarding the deficiencies in the internal control procedures and the corrective measures taken to address the deficiencies.

The Role of the Legal Department in the Framework of Internal Control

The legal department plays a vital and continuous role in banks, in order to ensure the compliance of the bank's activities with the laws and regulations, and this role requires the establishment of a legal framework and the availability of legal advice, in addition to limiting the legal risks that may lead to losses to the bank and reduce profits.

And to ensure the compliance of the department's activities and the prevention of its violations, the objectives of the department are:

The President/Head of the Legal Department is responsible for informing the management of the bank's activities and managing its relations with the relevant authorities, including the responsibility for the legal department's strategy and its alignment with the bank's strategy, provided that the strategy is implemented by qualified and specialized personnel, and that the legal department is aware of the laws and regulations and the bank's activities.

The role of the legal department is to ensure that the internal control system includes the following:

1. Providing legal opinions to the specialized departments, including the bank's policies and procedures, and the Central Bank of Egypt's regulations and the domestic bank's regulations.

2. Adopting the necessary procedures and measures to prevent the filing of lawsuits against the bank and the authorities concerned, in accordance with the bank's policies and procedures, and the authorities concerned, in accordance with the bank's policies and procedures.

3. Preparing, reviewing, and updating the legal documents for the bank's activities, including the contracts and agreements, and the legal documents for the bank's activities, and the legal documents for the bank's activities.

4. Adopting the necessary legal procedures for the bank's activities, including the mortgage procedures and the procedures for the realization of the collateral.

5. Ensuring the prevention and resolution of disputes and the adoption of the necessary measures regarding them.

6. Informing the risk management department, the senior management, and the internal control department of the bank of the legal risks that may affect the bank and the necessary provisions to address the risks and the violations of the laws and regulations.

7. Appointing other specialized personnel who have the necessary legal expertise.

1/8/1 External Support in Legal Aspects:

It is necessary to resort to external legal support in cases where the expertise is not available within the bank, or for the preparation of the documents for the bank's activities, and in these cases, the following must be observed:

1. The external support must be of high reputation and expertise in this field.

2. The external support must be independent and free from any conflicts of interest.

3. This must be done through the legal department / the external legal consultant with full expertise and authority to determine the objectives.

4. Taking into account the confidentiality of the account information and other legal information.

Second: Functions of Internal Control

2/1 Internal Audit

• The independence of the internal audit function is necessary to ensure the effectiveness of internal control and governance in the bank, in order to inform the risk management and internal control departments of the objectives of the Audit Committee and the senior management and the Board of Directors of the bank, in order to ensure the effectiveness and efficiency of the bank's procedures and the activities of the bank.

• The bank must have an internal audit function (Audit Charter) that specifies its role, and it must include the objectives and authorities of the function, and the separation of powers and responsibilities among the employees, and the internal audit function must be aware of the bank's activities, including the external support (Outsourcing).

• The internal audit function must be independent in its performance of its duties, and it must report to the Audit Committee and the Board of Directors of the bank, in accordance with the independence.

• The internal audit function must be staffed by qualified and experienced personnel, and the Head/Director of Internal Audit is responsible for the management and effectiveness of the internal audit function, and the ethical behavior of the employees.

• The Internal Audit Department must have 43 employees, in accordance with the Central Bank of Egypt's regulations on the appointment of the Head/Director of Internal Audit and the conditions for this position.

• The employees of the internal audit function must be qualified and experienced, and the internal audit function must ensure the confidentiality of the information and the avoidance of conflicts of interest, and the training of the employees in the latest developments in the field of internal audit.

2/1/1 Relationship of Internal Audit with External Supervisory Authorities

2/1/1/1 Central Bank of Egypt

• The bank's management must appoint a representative to the Head/Director of Internal Audit to coordinate with the supervisory authorities regarding the bank's activities.

• The regulations issued regarding the governance require the Audit Committee of the bank to prepare and submit a quarterly report to the Board of Directors, specifying the corrective measures taken for the identified deficiencies.

• The bank's management must coordinate with the supervisory authorities and provide the necessary information and reports, especially regarding the consolidated financial statements of the bank and its subsidiaries, and the external supervisory authorities, including the Central Bank of Egypt's consolidated financial statements.

2/1/1/2 External Auditors

• The Head of Internal Audit must coordinate with the external auditors, especially with the senior management and the Board of Directors and the Audit Committee, in accordance with the provisions of Article 84 of the Central Bank of Egypt's regulations.

• The Head of Internal Audit must provide the external auditors with the necessary information and reports, including the information required by the Central Bank of Egypt.

• The Head of Internal Audit must coordinate with the external auditors to ensure the effectiveness of the audit process and the identification of the risks and the corrective measures taken for this purpose, including the implementation of Article 27 of the Executive Bylaws of the Central Bank of Egypt.

2/1/2 Audit of Bank Branches and Units Abroad

The bank must ensure the adoption of the supervisory regulations regarding its branches and subsidiaries abroad, so that:

• The activities of the bank's branches and units abroad are aligned with the bank's objectives and strategies in accordance with the local regulations.

• The branches and units of the bank abroad comply with the regulations of the country in which they are located, and if the branches comply with the Central Bank of Egypt's regulations regarding the preparation and presentation of the financial statements, provided that the branch abroad informs the Head/Director of Internal Control of its activities in a timely manner, and the branch abroad informs the Central Bank of Egypt of its activities in a timely manner, in accordance with the necessary measures for this purpose.

• The branches and units of the bank abroad are subject to the applicable laws and regulations, and the employees' rights.

• The separation of powers to ensure the implementation of internal controls.

• The branches and units abroad must conduct internal audits and prepare reports on their activities to the Central Bank of Egypt's Internal Audit Department in accordance with the regulations.

• The banks must inform the supervisory authorities of the branch's activities in a timely manner in accordance with the supervisory regulations and the external auditors of the country in which the branch is located.

2/1/3 Audit of Service Providers and External Support Entities - Outsourcing

2/1/3/1 The bank must, at a minimum, observe the following in its policy for the use of external service providers:

• The use of external support must be subject to the internal audit of the external support and the bank.

• The bank must ensure that the external support provider has the necessary legal qualifications and experience to perform the external support.

• The regulations regarding the absence of conflict of interest must be observed.

2/1/3/2 The bank must ensure through its contract with external service providers the following:

• The quality of the services provided and the continuity of the services in case of emergencies.

• The confidentiality of the bank's information and the protection of the bank's interests.

• The preparation of a contingency plan to prevent the bank's activities from being interrupted in the event of the failure of the service provider, without prejudice to the Service Level Agreement (SLA) and the bank's right to terminate the contract in the event of a failure to meet the service standards.

• The service provider must not make any changes to the services provided without the bank's prior written consent.

• The bank must have the right to monitor the services provided by the service provider, including the periodic reports on the level of service provided.

• The service provider must ensure the confidentiality of the information provided to it by the bank, and the protection of the bank's interests.

• The service provider must inform the bank of any incidents that may affect the services provided to it, and the measures taken to address them.

• The service provider must inform the supervisory authorities and the Central Bank of Egypt - if required - of the information provided to it, including the financial statements.

2/2 Risk Management and Control

2/2/1 Risk Management

2/2/1/1 Elements of Risk Management

The risk management function in the bank is responsible for identifying, measuring, and monitoring the bank's risks, in order to define the risk appetite and the risk management strategy, and to prepare a risk management plan for the different types of risks in the bank (whether at the consolidated level or at the subsidiary level, and also at the activity level), including the degree of correlation between the different risks, such as the correlation between credit risk and market risk, and the correlation between credit risk and operational risk, and the overall risk level approved by the Board of Directors, in addition to the following:

• The establishment of procedures and limits for risk management, including the identification and measurement of the bank's activities and the continuous monitoring of its risks and the adoption of necessary measures in the event of any deviation from the approved limits, in accordance with the policies and procedures and the reporting to the Risk Committee and the Board of Directors, and the existence of a department for each type of main risk (credit risk, including the domestic subsidiary risk, market risk, operational risk, etc.) that is responsible for the identification and measurement of the risks and the establishment of the necessary procedures and measures to address the risks.

• The control and analysis of risks, including the identification of the different types of risks, whether inherent and/or residual risks, and the identification of the internal and external risk factors.

• The existence of a risk management policy that includes the limits and authorities for the risks and the monitoring and evaluation of the risks and the role of the Model Verification and Validation.

• The periodic review of the risks faced by the bank, especially the credit risk (counterparty and domestic subsidiary risk), market risk, and operational risk.

• The coordination and periodic reporting to the authorities regarding the coordination between the risk management policies and the financial statements and the regulatory requirements.

• The establishment of procedures for the identification of risk management, including the existence of contingency plans (business continuity, liquidity, etc.).

• The establishment of procedures for the monitoring of the risk levels to define their role.

• The organizational structure of the risk management function in the bank must be consistent with the human resources management.

• The risk management function must include stress testing procedures, including the stress testing of the bank's activities (whether the branches of the bank, the subsidiaries, or the consolidated financial statements), including the identification of the risks and the scenarios, and the identification of the risks and the scenarios, and the identification of the risks and the scenarios, and the identification of the risks and the scenarios, and the identification of the risks and the scenarios, and the identification of the risks and the scenarios, and the identification of the risks and the scenarios, and the identification of the risks and the scenarios, and the identification of the risks and the scenarios, and the identification of the risks and the scenarios, and the identification of the risks and the scenarios, and the identification of the risks and the scenarios, and the identification of the risks and the scenarios, and the identification of the risks and the scenarios, and 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identification of the risks and the scenarios, and the identification of the risks and the scenarios, and the identification of the risks and the scenarios, and the identification of the risks and the scenarios, and the identification of the risks and the scenarios, and the identification of the risks and the scenarios, and the identification of the risks and the scenarios, and the identification of the risks and the scenarios, and the identification of the risks and the scenarios, and the identification of the risks and the scenarios, and the identification of the risks and the scenarios, and the identification of the risks and the scenarios, and the identification of the risks and the scenarios, and the identification of the risks and the scenarios, and the identification of the risks and the scenarios, and the identification of the risks and the scenarios, and the identification of the risks and the scenarios, and the identification of the risks and the scenarios, and the identification of the risks and the scenarios, and the identification of the risks and the scenarios, and the identification of the risks and the scenarios, and the identification of the risks and the scenarios, and the identification of the risks and the scenarios, and the identification of the risks and the scenarios, and the identification of the risks and the scenarios, and the identification of the risks and the scenarios, and the identification of the risks and the scenarios, and the identification of the risks and the scenarios, and the identification of the risks and the scenarios, and the identification of the risks and the scenarios, and the identification of the risks and the scenarios, and the identification of the risks and the scenarios, and the identification of the risks and the scenarios, and the identification of the risks and the scenarios, and the identification of the risks and the scenarios, and the identification of the risks and the scenarios, and the identification of the risks and the scenarios, and the identification of the risks and the scenarios, and the identification of the risks and the scenarios, and the identification of the risks and the scenarios, and the identification of the risks and the scenarios, and the identification of the risks and the scenarios, and the identification of the risks and the scenarios, and the identification of the risks and the scenarios, and the identification of the risks and the scenarios, and the identification of the risks and the scenarios, and the identification of the risks and the scenarios, and the identification of the risks and the scenarios, and the identification of the risks and the scenarios, and the identification of the risks and the scenarios, and the identification of the risks and the scenarios, and the identification of the risks and the scenarios, and the identification of the risks and the scenarios, and the identification of the risks and the scenarios, and the identification of the risks and the scenarios, and the identification of the risks and the scenarios, and the identification of the risks and the scenarios, and the identification of the risks and the scenarios, and the identification of the risks and the scenarios, and the identification of the risks and the scenarios, and the identification of the risks and the scenarios, and the identification of the risks and the scenarios, and the identification of the risks and the scenarios, and the identification of the risks and the scenarios, and the identification of the risks and the scenarios, and the identification of the risks and the scenarios, and the identification of the risks and the scenarios, and the identification of the risks and the scenarios, and the identification of the risks and the scenarios, and the identification of the risks and the scenarios, and the identification of the risks and the scenarios, and the identification of the risks and the scenarios, and the identification of the risks and the scenarios, and the identification of the risks and the scenarios, and the identification of the risks and the scenarios, and the identification of the risks and the scenarios, and the identification of the risks and the scenarios, and the identification of the risks and the scenarios, and the identification of the risks and the scenarios, and the identification of the risks and the scenarios, and the identification of the risks and the scenarios, and the identification of the risks and the scenarios, and the identification of the risks and the scenarios, and the identification of the risks and the scenarios, and the identification of the risks and the scenarios, and the identification of the risks and the scenarios, and the identification of the risks and the scenarios, and the identification of the risks and the scenarios, and the identification of the risks and the scenarios, and the identification of the risks and the scenarios, and the identification of the risks and the scenarios, and the identification of the risks and the scenarios, and the identification of the risks and the scenarios, and the identification of the risks and the scenarios, and the identification of the risks and the scenarios, and the identification of the risks and the scenarios, and the identification of the risks and the scenarios, and the identification of the risks and the scenarios, and the identification of the risks and the scenarios, and the identification of the risks and the scenarios, and the identification of the risks and the scenarios, and the identification of the risks and the scenarios, and the identification of the risks and the scenarios, and the identification of the risks and the scenarios, and the identification of the risks and the scenarios, and the identification of the risks and the scenarios, and the identification of the risks and the scenarios, and the identification of the risks and the scenarios, and the identification of the risks and the scenarios, and the identification of the risks and the scenarios, and the identification of the risks and the scenarios, and the identification of the risks and the scenarios, and the identification of the risks and the scenarios, and the identification of the risks and the scenarios, and the identification of the risks and the scenarios, and the identification of the risks and the scenarios, and the identification of the risks and the scenarios, and the identification of the risks and the scenarios, and the identification of the risks and the scenarios, and the identification of the risks and the scenarios, and the identification of the risks and the scenarios, and the identification of the risks and the scenarios, and the identification of the risks and the scenarios, and the identification of the risks and the scenarios, and the identification of the risks and the scenarios, and the identification of the risks and the scenarios, and the identification of the risks and the scenarios, and the identification of the risks and the scenarios, and the identification of the risks and the scenarios, and the identification of the risks and the scenarios, and the identification of the risks and the scenarios, and the identification of the risks and the scenarios, and the identification of the risks and the scenarios, and the identification of the risks and the scenarios, and the identification of the risks and the scenarios, and the identification of the risks and the scenarios, and the identification of the risks and the scenarios, and the identification of the risks and the scenarios, and the identification of the risks and the scenarios, and the identification of the risks and the scenarios, and the identification of the risks and the scenarios, and the identification of the risks and the scenarios, and the identification of the risks and the scenarios, and the identification of the risks and the scenarios, and the identification of the risks and the scenarios, and the identification of the risks and the scenarios, and the identification of the risks and the scenarios, and the identification of the risks and the scenarios, and the identification of the risks and the scenarios, and the identification of the risks and the scenarios, and the identification of the risks and the scenarios, and the identification of the risks and the scenarios, and the identification of the risks and the scenarios, and the identification of the risks and the scenarios, and the identification of the risks and the scenarios, and the identification of the risks and the scenarios, and the identification of the risks and the scenarios, and the identification of the risks and the scenarios, and the identification of the risks and the scenarios, and the identification of the risks and the scenarios, and the identification of the risks and the scenarios, and the identification of the risks and the scenarios, and the identification of the risks and the scenarios, and the identification of the risks and the scenarios, and the identification of the risks and the scenarios, and the identification of the risks and the scenarios, and the identification of the risks and the scenarios, and the identification of the risks and the scenarios, and the identification of the risks and the scenarios, and the identification of the risks and the scenarios, and the identification of the risks and the scenarios, and the identification of the risks and the scenarios, and the identification of the risks and the scenarios, and the identification of the risks and the scenarios, and the identification of the risks and the scenarios, and the identification of the risks and the scenarios, and the identification of the risks and the scenarios, and the identification of the risks and the scenarios, and the identification of the risks and the scenarios, and the identification of the risks and the scenarios, and the identification of the risks and the scenarios, and the identification of the risks and the scenarios, and the identification of the risks and the scenarios, and the identification of the risks and the scenarios, and the identification of the risks and the scenarios, and the identification of the risks and the scenarios, and the identification of the risks and the scenarios, and the identification of the risks and the scenarios, and the identification of the risks and the scenarios, and the identification of the risks and the scenarios, and the identification of the risks and the scenarios, and the identification of the risks and the scenarios, and the identification of the risks and the scenarios, and the identification of the risks and the scenarios, and the identification of the risks and the scenarios, and the identification of the risks and the scenarios, and the identification of the risks and the scenarios, and the identification of the risks and the scenarios, and the identification of the risks and the scenarios, and the identification of the risks and the scenarios, and the identification of the risks and the scenarios, and the identification of the risks and the scenarios, and the identification of the risks and the scenarios, and the identification of the risks and the scenarios, and the identification of the risks and the scenarios, and the identification of the risks and the scenarios, and the identification of the risks and the scenarios, and the identification of the risks and the scenarios, and the identification of the risks and the scenarios, and the identification of the risks and the scenarios, and the identification of the risks and the scenarios, and the identification of the risks and the scenarios, and the identification of the risks and the scenarios, and the identification of the risks and the scenarios, and the identification of the risks and the scenarios, and the identification of the risks and the scenarios, and the identification of the risks and the scenarios, and the identification of the risks and the scenarios, and the identification of the risks and the scenarios, and the identification of the risks and the scenarios, and the identification of the risks and the scenarios, and the identification of the risks and the scenarios, and the identification of the risks and the scenarios, and the identification of the risks and the scenarios, and the identification of the risks and the scenarios, and the identification of the risks and the scenarios, and the identification of the risks and the scenarios, and the identification of the risks and the scenarios, and the identification of the risks and the scenarios, and the identification of the risks and the scenarios, and the identification of the risks and the scenarios, and the identification of the risks and the scenarios, and the identification of the risks and the scenarios, and the identification of the risks and the scenarios, and the identification of the risks and the scenarios, and the identification of the risks and the scenarios, and the identification of the risks and the scenarios, and the identification of the risks and the scenarios, and the identification of the risks and the scenarios, and the identification of the risks and the scenarios, and the identification of the risks and the scenarios, and the identification of the risks and the scenarios, and the identification of the risks and the scenarios, and the identification of the risks and the scenarios, and the identification of the risks and the scenarios, and the identification of the risks and the scenarios, and the identification of the risks and the scenarios, and the identification of the risks and the scenarios, and the identification of the risks and the scenarios, and the identification of the risks and the scenarios, and the identification of the risks and the scenarios, and the identification of the risks and the scenarios, and the identification of the risks and the scenarios, and the identification of the risks and the scenarios, and the identification of the risks and the scenarios, and the identification of the risks and the scenarios, and the identification of the risks and the scenarios, and the identification of the risks and the scenarios, and the identification of the risks and the scenarios, and the identification of the risks and the scenarios, and the identification of the risks and the scenarios, and the identification of the risks and the scenarios, and the identification of the risks and the scenarios, and the identification of the risks and the scenarios, and the identification of the risks and the scenarios, and the identification of the risks and the scenarios, and the identification of the risks and the scenarios, and the identification of the risks and the scenarios, and the identification of the risks and the scenarios, and the identification of the risks and the scenarios, and the identification of the risks and the scenarios, and the identification of the risks and the scenarios, and the identification of the risks and the scenarios, and the identification of the risks and the scenarios, and the identification of the risks and the scenarios, and the identification of the risks and the scenarios, and the identification of the risks and the scenarios, and the identification of the risks and the scenarios, and the identification of the risks and the scenarios, and the identification of the risks and the scenarios, and the identification of the risks and the scenarios, and the identification of the risks and the scenarios, and the identification of the risks and the scenarios, and the identification of the risks and the scenarios, and the identification of the risks and the scenarios, and the identification of the risks and the scenarios, and the identification of the risks and the scenarios, and the identification of the risks and the scenarios, and the identification of the risks and the scenarios, and the identification of the risks and the scenarios, and the identification of the risks and the scenarios, and the identification of the risks and the scenarios, and the identification of the risks and the scenarios, and the identification of the risks and the scenarios, and the identification of the risks and the scenarios, and the identification of the risks and the scenarios, and the identification of the risks and the scenarios, and the identification of the risks and the scenarios, and the identification of the risks and the scenarios, and the identification of the risks and the scenarios, and the identification of the risks and the scenarios, and the identification of the risks and the scenarios, and the identification of the risks and the scenarios, and the identification of the risks and the scenarios, and the identification of the risks and the scenarios, and the identification of the risks and the scenarios, and the identification of the risks and the scenarios, and the identification of the risks and the scenarios, and the identification of the risks and the scenarios, and the identification of the risks and the scenarios, and the identification of the risks and the scenarios, and the identification of the risks and the scenarios, and the identification of the risks and the scenarios, and the identification of the risks and the scenarios, and the identification of the risks and the scenarios, and the identification of the risks and the scenarios, and the identification of the risks and the scenarios, and the identification of the risks and the scenarios, and the identification of the risks and the scenarios, and the identification of the risks and the scenarios, and the identification of the risks and the scenarios, and the identification of the risks and the scenarios, and the identification of the risks and the scenarios, and the identification of the risks and the scenarios, and the identification of the risks and the scenarios, and the identification of the risks and the scenarios, and the identification of the risks and the scenarios, and the identification of the risks and the scenarios, and the identification of the risks and the scenarios, and the identification of the risks and the scenarios, and the identification of the risks and the scenarios, and the identification of the risks and the scenarios, and the identification of the risks and the scenarios, and the identification of the risks and the scenarios, and the identification of the risks and the scenarios, and the identification of the risks and the scenarios, and the identification of the risks and the scenarios, and the identification of the risks and the scenarios, and the identification of the risks and the scenarios, and the identification of the risks and the scenarios, and the identification of the risks and the scenarios, and the identification of the risks and the scenarios, and the identification of the risks and the scenarios, and the identification of the risks and the scenarios, and the identification of the risks and the scenarios, and the identification of the risks and the scenarios, and the identification of the risks and the scenarios, and the identification of the risks and the scenarios, and the identification of the risks and the scenarios, and the identification of the risks and the scenarios, and the identification of the risks and the scenarios, and the identification of the risks and the scenarios, and the identification of the risks and the scenarios, and the identification of the risks and the scenarios, and the identification of the risks and the scenarios, and the identification of the risks and the scenarios, and the identification of the risks and the scenarios, and the identification of the risks and the scenarios, and the identification of the risks and the scenarios, and the identification of the risks and the scenarios, and the identification of the risks and the scenarios, and the identification of the risks and the scenarios, and the identification of the risks and the scenarios, and the identification of the risks and the scenarios, and the identification of the risks and the scenarios, and the identification of the risks and the scenarios, and the identification of the risks and the scenarios, and the identification of the risks and the scenarios, and the identification of the risks and the scenarios, and the identification of the risks and the scenarios, and the identification of the risks and the scenarios, and the identification of the risks and the scenarios, and the identification of the risks and the scenarios, and the identification of the risks and the scenarios, and the identification of the risks and the scenarios, and the identification of the risks and the scenarios, and the identification of the risks and the scenarios, and the identification of the risks and the scenarios, and the identification of the risks and the scenarios, and the identification of the risks and the scenarios, and the identification of the risks and the scenarios, and the identification of the risks and the scenarios, and the identification of the risks and the scenarios, and the identification of the risks and the scenarios, and the identification of the risks and the scenarios, and the identification of the risks and the scenarios, and the identification of the risks and the scenarios, and the identification of the risks and the scenarios, and the identification of the risks and the scenarios, and the identification of the risks and the scenarios, and the identification of the risks and the scenarios, and the identification of the risks and the scenarios, and the identification of the risks and the scenarios, and the identification of the risks and the scenarios, and the identification of the risks and the scenarios, and the identification of the risks and the scenarios, and the identification of the risks and the scenarios, and the identification of the risks and the scenarios, and the identification of the risks and the scenarios, and the identification of the risks and the scenarios, and the identification of the risks and the scenarios, and the identification of the risks and the scenarios, and the identification of the risks and the scenarios, and the identification of the risks and the scenarios, and the identification of the risks and the scenarios, and the identification of the risks and the scenarios, and the identification of the risks and the scenarios, and the identification of the risks and the scenarios, and the identification of the risks and the scenarios, and the identification of the risks and the scenarios, and the identification of the risks and the scenarios, and the identification of the risks and the scenarios, and the identification of the risks and the scenarios, and the identification of the risks and the scenarios, and the identification of the risks and the scenarios, and the identification of the risks and the scenarios, and the identification of the risks and the scenarios, and the identification of the risks and the scenarios, and the identification of the risks and the scenarios, and the identification of the risks and the scenarios, and the identification of the risks and the scenarios, and the identification of the risks and the scenarios, and the identification of the risks and the scenarios, and the identification of the risks and the scenarios, and the identification of the risks and the scenarios, and the identification of the risks and the scenarios, and the identification of the risks and the scenarios, and the identification of the risks and the scenarios, and the identification of the risks and the scenarios, and the identification of the risks and the scenarios, and the identification of the risks and the scenarios, and the identification of the risks and the scenarios, and the identification of the risks and the scenarios, and the identification of the risks and the scenarios, and the identification of the risks and the scenarios, and the identification of the risks and the scenarios, and the identification of the risks and the scenarios, and the identification of the risks and the scenarios, and the identification of the risks and the scenarios, and the identification of the risks and the scenarios, and the identification of the risks and the scenarios, and the identification of the risks and the scenarios, and the identification of the risks and the scenarios, and the identification of the risks and the scenarios, and the identification of the risks and the scenarios, and the identification of the risks and the scenarios, and the identification of the risks and the scenarios, and the identification of the risks and the scenarios, and the identification of the risks and the scenarios, and the identification of the risks and the scenarios, and the identification of the risks and the scenarios, and the identification of the risks and the scenarios, and the identification of the risks and the scenarios, and the identification of the risks and the scenarios, and the identification of the risks and the scenarios, and the identification of the risks and the scenarios, and the identification of the risks and the scenarios, and the identification of the risks and the scenarios, and the identification of the risks and the scenarios, and the identification of the risks and the scenarios, and the identification of the risks and the scenarios, and the identification of the risks and the scenarios, and the identification of the risks and the scenarios, and the identification of the risks and the scenarios, and the identification of the risks and the scenarios, and the identification of the risks and the scenarios, and the identification of the risks and the scenarios, and the identification of the risks and the scenarios, and the identification of the risks and the scenarios, and the identification of the risks and the scenarios, and the identification of the risks and the scenarios, and the identification of the risks and the scenarios, and the identification of the risks and the scenarios, and the identification of the risks and the scenarios, and the identification of the risks and the scenarios, and the identification of the risks and the scenarios, and the identification of the risks and the scenarios, and the identification of the risks and the scenarios, and the identification of the risks and the scenarios, and the identification of the risks and the scenarios, and the identification of the risks and the scenarios, and the identification of the risks and the scenarios, and the identification of the risks and the scenarios, and the identification of the risks and the scenarios, and the identification of the risks and the scenarios, and the identification of the risks and the scenarios, and the identification of the risks and the scenarios, and the identification of the risks and the scenarios, and the identification of the risks and the scenarios, and the identification of the risks and the scenarios, and the identification of the risks and the scenarios, and the identification of the risks and the scenarios, and the identification of the risks and the scenarios, and the identification of the risks and the scenarios, and the identification of the risks and the scenarios, and the identification of the risks and the scenarios, and the identification of the risks and the scenarios, and the identification of the risks and the scenarios, and the identification of the risks and the scenarios, and the identification of the risks and the scenarios, and the identification of the risks and the scenarios, and the identification of the risks and the scenarios, and the identification of the risks and the scenarios, and the identification of the risks and the scenarios, and the identification of the risks and the scenarios, and the identification of the risks and the scenarios, and the identification of the risks and the scenarios, and the identification of the risks and the scenarios, and the identification of the risks and the scenarios, and the identification of the risks and the scenarios, and the identification of the risks and the scenarios, and the identification of the risks and the scenarios, and the identification of the risks and the scenarios, and the identification of the risks and the scenarios, and the identification of the risks and the scenarios, and the identification of the risks and the scenarios, and the identification of the risks and the scenarios, and the identification of the risks and the scenarios, and the identification of the risks and the scenarios, and the identification of the risks and the scenarios, and the identification of the risks and the scenarios, and the identification of the risks and the scenarios, and the identification of the risks and the scenarios, and the identification of the risks and the scenarios, and the identification of the risks and the scenarios, and the identification of the risks and the scenarios, and the identification of the risks and the scenarios, and the identification of the risks and the scenarios, and the identification of the risks and the scenarios, and the identification of the risks and the scenarios, and the identification of the risks and the scenarios, and the identification of the risks and the scenarios, and the identification of the risks and the scenarios, and the identification of the risks and the scenarios, and the identification of the risks and the scenarios, and the identification of the risks and the scenarios, and the identification of the risks and the scenarios, and the identification of the risks and the scenarios, and the identification of the risks and the scenarios, and the identification of the risks and the scenarios, and the identification of the risks and the scenarios, and the identification of the risks and the scenarios, and the identification of the risks and the scenarios, and the identification of the risks and the scenarios, and the identification of the risks and the scenarios, and the identification of the risks and the scenarios, and the identification of the risks and the scenarios, and the identification of the risks and the scenarios, and the identification of the risks and the scenarios, and the identification of the risks and the scenarios, and the identification of the risks and the scenarios, and the identification of the risks and the scenarios, and the identification of the risks and the scenarios, and the identification of the risks and the scenarios, and the identification of the risks and the scenarios, and the identification of the risks and the scenarios, and the identification of the risks and the scenarios, and the identification of the risks and the scenarios, and the identification of the risks and the scenarios, and the identification of the risks and the scenarios, and the identification of the risks and the scenarios, and the identification of the risks and the scenarios, and the identification of the risks and the scenarios, and the identification of the risks and the scenarios, and the identification of the risks and the scenarios, and the identification of the risks and the scenarios, and the identification of the risks and the scenarios, and the identification of the risks and the scenarios, and the identification of the risks and the scenarios, and the identification of the risks and the scenarios, and the identification of the risks and the scenarios, and the identification of the risks and the scenarios, and the identification of the risks and the scenarios, and the identification of the risks and the scenarios, and the identification of the risks and the scenarios, and the identification of the risks and the scenarios, and the identification of the risks and the scenarios, and the identification of the risks and the scenarios, and the identification of the risks and the scenarios, and the identification of the risks and the scenarios, and the identification of the risks and the scenarios, and the identification of the risks and the scenarios, and the identification of the risks and the scenarios, and the identification of the risks and the scenarios, and the identification of the risks and the scenarios, and the identification of the risks and the scenarios, and the identification of the risks and the scenarios, and the identification of the risks and the scenarios, and the identification of the risks and the scenarios, and the identification of the risks and the scenarios, and the identification of the risks and the scenarios, and the identification of the risks and the scenarios, and the identification of the risks and the scenarios, and the identification of the risks and the scenarios, and the identification of the risks and the scenarios, and the identification of the risks and the scenarios, and the identification of the risks and the scenarios, and the identification of the risks and the scenarios, and the identification of the risks and the scenarios, and the identification of the risks and the scenarios, and the identification of the risks and the scenarios, and the identification of the risks and the scenarios, and the identification of the risks and the scenarios, and the identification of the risks and the scenarios, and the identification of the risks and the scenarios, and the identification of the risks and the scenarios, and the identification of the risks and the scenarios, and the identification of the risks and the scenarios, and the identification of the risks and the scenarios, and the identification of the risks and the scenarios, and the identification of the risks and the scenarios, and the identification of the risks and the scenarios, and the identification of the risks and the scenarios, and the identification of the risks and the scenarios, and the identification of the risks and the scenarios, and the identification of the risks and the scenarios, and the identification of the risks and the scenarios, and the identification of the risks and the scenarios, and the identification of the risks and the scenarios, and the identification of the risks and the scenarios, and the identification of the risks and the scenarios, and the identification of the risks and the scenarios, and the identification of the risks and the scenarios, and the identification of the risks and the scenarios, and the identification of the risks and the scenarios, and the identification of the risks and the scenarios, and the identification of the risks and the scenarios, and the identification of the risks and the scenarios, and the identification of the risks and the scenarios, and the identification of the risks and the scenarios, and the identification of the risks and the scenarios, and the identification of the risks and the scenarios, and the identification of the risks and the scenarios, and the identification of the risks and the scenarios, and the identification of the risks and the scenarios, and the identification of the risks and the scenarios, and the identification of the risks and the scenarios, and the identification of the risks and the scenarios, and the identification of the risks and the scenarios, and the identification of the risks and the scenarios, and the identification of the risks and the scenarios, and the identification of the risks and the scenarios, and the identification of the risks and the scenarios, and the identification of the risks and the scenarios, and the identification of the risks and the scenarios, and the identification of the risks and the scenarios, and the identification of the risks and the scenarios, and the identification of the risks and the scenarios, and the identification of the risks and the scenarios, and the identification of the risks and the scenarios, and the identification of the risks and the scenarios, and the identification of the risks and the scenarios, and the identification of the risks and the scenarios, and the identification of the risks and the scenarios, and the identification of the risks and the scenarios, and the identification of the risks and the scenarios, and the identification of the risks and the scenarios, and the identification of the risks and the scenarios, and the identification of the risks and the scenarios, and the identification of the risks and the scenarios, and the identification of the risks and the scenarios, and the identification of the risks and the scenarios, and the identification of the risks and the scenarios, and the identification of the risks and the scenarios, and the identification of the risks and the scenarios, and the identification of the risks and the scenarios, and the identification of the risks and the scenarios, and the identification of the risks and the scenarios, and the identification of the risks and the scenarios, and the identification of the risks and the scenarios, and the identification of the risks and the scenarios, and the identification of the risks and the scenarios, and the identification of the risks and the scenarios, and the identification of the risks and the scenarios, and the identification of the risks and the scenarios, and the identification of the risks and the scenarios, and the identification of the risks and the scenarios, and the identification of the risks and the scenarios, and the identification of the risks and the scenarios, and the identification of the risks and the scenarios, and the identification of the risks and the scenarios, and the identification of the risks and the scenarios, and the identification of the risks and the scenarios, and the identification of the risks and the scenarios, and the identification of the risks and the scenarios, and the identification of the risks and the scenarios, and the identification of the risks and the scenarios, and the identification of the risks and the scenarios, and the identification of the risks and the scenarios, and the identification of the risks and the scenarios, and the identification of the risks and the scenarios, and the identification of the risks and the scenarios, and the identification of the risks and the scenarios, and the identification of the risks and the scenarios, and the identification of the risks and the scenarios, and the identification of the risks and the scenarios, and the identification of the risks and the scenarios, and the identification of the risks and the scenarios, and the identification of the risks and the scenarios, and the identification of the risks and the scenarios, and the identification of the risks and the scenarios, and the identification of the risks and the scenarios, and the identification of the risks and the scenarios, and the identification of the risks and the scenarios, and the identification of the risks and the scenarios, and the identification of the risks and the scenarios, and the identification of the risks and the scenarios, and the identification of the risks and the scenarios, and the identification of the risks and the scenarios, and the identification of the risks and the scenarios, and the identification of the risks and the scenarios, and the identification of the risks and the scenarios, and the identification of the risks and the scenarios, and the identification of the risks and the scenarios, and the identification of the risks and the scenarios, and the identification of the risks and the scenarios, and the identification of the risks and the scenarios, and the identification of the risks and the scenarios, and the identification of the risks and the scenarios, and the identification of the risks and the scenarios, and the 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