Halden reports / Risk
Halden report · Risk
Which risks need attention?
Two of Halden's 79 risks: coverholders binding outside authority and the UAE fronting partner's claims handling, both rated high after controls.
CoVi · Risk register Fictitious
Halden risk register
Halden's risk register, built by Context Visualised: one register across the managing agent, both syndicates and the owned coverholder in Dubai. Data at 30 September 2026.
79 / 79 Risks showing 2 High residual 24 Risks with controls not fully effective Library: 26 controls not fully effective (2 ineffective, 24 partial) Class All Insurance Market Counterparty Strategic Operational
Entity All Managing agent 9146 9147 Dubai
Residual rating All High Medium Low
OwnerAll owners Chief Actuary Chief Data Officer Chief Executive Officer Chief Financial Officer Chief Information Officer Chief Information Security Officer Chief Operating Officer Chief Risk Officer Chief Underwriting Officer Company Secretary Dubai Chief Executive Dubai Compliance Officer Head of Capital Head of Claims Head of Compliance Head of Delegated Authority Head of Exposure Management Head of HR Head of Product Head of Reinsurance Head of Tax Money Laundering Reporting Officer Clear filters
ID Risk Class › subclass Entities Owner Inherent Residual Controls
No risks match these filters.
OR-06.1 Coverholder binding outside authority Coverholders bind risks outside their agreed limits, classes or territories. Class OperationalOutsourcing and third parties Entities Syn 9146 · DubaiOwner Head of Delegated AuthorityInherent 16 · High Residual 16 · High Controls Ineffective Key controls Key risk indicator Out-of-authority binding
Scoring Inherent L4 × I4 → residual L4 × I4
Outside appetite: action required
OR-06.2 Fronting partner claims handling failure The UAE fronting insurer delays or mishandles claims that we ultimately pay. Class OperationalOutsourcing and third parties Entities Syn 9146 · DubaiOwner Head of ClaimsInherent 16 · High Residual 16 · High Controls Ineffective Key controls Key risk indicator Fronted claims settled outside agreed timescales
Scoring Inherent L4 × I4 → residual L4 × I4
Outside appetite: action required
IR-01.3 Social inflation in US casualty Rising US jury awards outpace casualty rate increases. Class InsurancePremium Entities Syn 9147Owner Chief Underwriting OfficerInherent 16 · High Residual 12 · Medium Controls Partially effective Key controls Key risk indicator US casualty severity trend
Scoring Inherent L4 × I4 → residual L3 × I4
Within tolerance, monitor closely
IR-02.1 Long-tail casualty reserve inadequacy Casualty reserves prove too low as claims develop over many years. Class InsuranceReserving Entities Syn 9147Owner Chief ActuaryInherent 15 · High Residual 12 · Medium Controls Partially effective Key controls Key risk indicator Actual vs expected claims development
Scoring Inherent L3 × I5 → residual L3 × I4
Within tolerance, monitor closely
IR-03.2 Systemic cyber accumulation One cyber event triggers losses across many policies at once. Class InsuranceCatastrophe Entities Syn 9146 · Syn 9147Owner Head of Exposure ManagementInherent 15 · High Residual 12 · Medium Controls Partially effective Key controls Key risk indicator Cyber PML vs tolerance
Scoring Inherent L3 × I5 → residual L3 × I4
Within tolerance, monitor closely
IR-01.4 Adverse selection in growth classes Fast growth in casualty and reinsurance attracts poorer-quality risks. Class InsurancePremium Entities Syn 9147 · Syn 9146Owner Chief Underwriting OfficerInherent 16 · High Residual 9 · Medium Controls Partially effective Key controls Key risk indicator Loss ratio on new vs renewal business
Scoring Inherent L4 × I4 → residual L3 × I3
Within appetite
IR-03.3 Climate-driven loss frequency and severity Warming increases the frequency and cost of weather losses beyond models. Class InsuranceCatastrophe Entities Syn 9146Owner Head of Exposure ManagementInherent 16 · High Residual 9 · Medium Controls Partially effective Key controls Key risk indicator Secondary peril losses vs model
Scoring Inherent L4 × I4 → residual L3 × I3
Within appetite
IR-01.5 Softening market cycle Rates fall faster than planned and erode margins. Class InsurancePremium Entities Syn 9146 · Syn 9147Owner Chief Underwriting OfficerInherent 12 · Medium Residual 9 · Medium Controls Partially effective Key controls Key risk indicator Risk-adjusted rate change
Scoring Inherent L4 × I3 → residual L3 × I3
Within appetite
IR-05.1 Concentration in Gulf energy Middle East growth concentrates exposure in a few large energy sites. Class InsuranceAccumulation & aggregation Entities Syn 9146 · DubaiOwner Chief Underwriting OfficerInherent 12 · Medium Residual 9 · Medium Controls Partially effective Key controls Key risk indicator Top-10 Gulf energy aggregates
Scoring Inherent L3 × I4 → residual L3 × I3
Within appetite
SR-01.1 Failure to deliver the 2027 growth plan The 10% growth plan stalls or is delivered at poor margin. Class StrategicExecution Entities Managing agentOwner Chief Executive OfficerInherent 12 · Medium Residual 9 · Medium Controls Partially effective Key controls Key risk indicator Strategic milestones on track
Scoring Inherent L3 × I4 → residual L3 × I3
Within appetite
SR-01.4 Plan profit not achieved Results fall short of the £75m plan profit. Class StrategicExecution Entities Syn 9146 · Syn 9147Owner Chief Financial OfficerInherent 12 · Medium Residual 9 · Medium Controls Partially effective Key controls Key risk indicator Forecast profit vs plan
Scoring Inherent L3 × I4 → residual L3 × I3
Within appetite
SR-02.1 Policy system replacement fails The new policy administration system is late, over budget or loses data. Class StrategicChange Entities Managing agentOwner Chief Operating OfficerInherent 12 · Medium Residual 9 · Medium Controls Partially effective Key controls Key risk indicator Milestones slipped
Scoring Inherent L3 × I4 → residual L3 × I3
Within appetite
SR-02.2 Growth outpaces infrastructure Growth strains underwriting, claims and data capacity. Class StrategicChange Entities Managing agentOwner Chief Executive OfficerInherent 12 · Medium Residual 9 · Medium Controls Partially effective Key controls Key risk indicator Headcount vs volume growth
Scoring Inherent L3 × I4 → residual L3 × I3
Within appetite
OR-08.1 Poor quality underwriting data Incomplete or inaccurate policy data undermines pricing and exposure management. Class OperationalData and models Entities Syn 9146 · Syn 9147Owner Chief Data OfficerInherent 12 · Medium Residual 9 · Medium Controls Partially effective Key controls Key risk indicator Policies missing critical fields
Scoring Inherent L4 × I3 → residual L3 × I3
Within appetite
CR-01.3 Reinsurance cost and availability Outwards protection becomes more expensive or unavailable at renewal. Class CounterpartyReinsurance Entities Syn 9146 · Syn 9147Owner Head of ReinsuranceInherent 9 · Medium Residual 9 · Medium Controls Partially effective Key controls Key risk indicator Reinsurance spend as % of GWP
Scoring Inherent L3 × I3 → residual L3 × I3
Within appetite
SR-01.3 Dubai platform underdelivers The Middle East growth plan is missed or achieved at poor margin. Class StrategicExecution Entities DubaiOwner Dubai Chief ExecutiveInherent 9 · Medium Residual 9 · Medium Controls Partially effective Key controls Key risk indicator Dubai GWP and loss ratio vs plan
Scoring Inherent L3 × I3 → residual L3 × I3
Within appetite
SR-05.1 New capital and MGAs compress margins New entrants push down rates and take lead positions. Class StrategicCompetitive environment Entities Managing agentOwner Chief Executive OfficerInherent 9 · Medium Residual 9 · Medium Controls Partially effective Key controls Key risk indicator Lead share on key accounts
Scoring Inherent L3 × I3 → residual L3 × I3
Within appetite
OR-03.2 Insufficient resource for growth Teams cannot keep pace with planned growth. Class OperationalPeople Entities Managing agentOwner Head of HRInherent 9 · Medium Residual 9 · Medium Controls Partially effective Key controls Key risk indicator Vacancy rate in key teams
Scoring Inherent L3 × I3 → residual L3 × I3
Within appetite
OR-06.3 Weak coverholder oversight Monitoring of the coverholder network is too infrequent or shallow. Class OperationalOutsourcing and third parties Entities Syn 9146 · Syn 9147Owner Head of Delegated AuthorityInherent 9 · Medium Residual 9 · Medium Controls Partially effective Key controls Key risk indicator Coverholder audits overdue
Scoring Inherent L3 × I3 → residual L3 × I3
Within appetite
OR-08.2 Uncontrolled AI in underwriting and claims AI tools are used without validation, explainability or data controls. Class OperationalData and models Entities Managing agentOwner Chief Data OfficerInherent 9 · Medium Residual 9 · Medium Controls Partially effective Key controls Key risk indicator Unregistered AI tools found
Scoring Inherent L3 × I3 → residual L3 × I3
Within appetite
OR-02.1 Ransomware attack Attackers encrypt systems and demand payment. Class OperationalCyber Entities Managing agentOwner Chief Information Security OfficerInherent 20 · High Residual 8 · Medium Controls Effective Key controls Key risk indicator Critical vulnerabilities unpatched over 30 days
Scoring Inherent L4 × I5 → residual L2 × I4
Within appetite
IR-03.1 Natural catastrophe accumulation A major event exceeds modelled losses across property and reinsurance. Class InsuranceCatastrophe Entities Syn 9146Owner Head of Exposure ManagementInherent 15 · High Residual 8 · Medium Controls Effective Key controls Key risk indicator 1-in-200 net cat loss vs appetite
Scoring Inherent L3 × I5 → residual L2 × I4
Within appetite
OR-07.1 Sanctions breach A risk or claim involves a sanctioned party, a heightened exposure in Middle East business. Class OperationalFinancial crime Entities Syn 9146 · DubaiOwner Money Laundering Reporting OfficerInherent 15 · High Residual 8 · Medium Controls Effective Key controls Key risk indicator Screening alerts open over five days
Scoring Inherent L3 × I5 → residual L2 × I4
Within appetite
IR-01.2 Inadequate pricing Rates fail to cover expected losses, expenses and the cost of capital. Class InsurancePremium Entities Syn 9146 · Syn 9147Owner Chief ActuaryInherent 12 · Medium Residual 8 · Medium Controls Effective Key controls Key risk indicator Rate change vs plan assumption
Scoring Inherent L3 × I4 → residual L2 × I4
Within appetite
SR-03.2 Loss of third-party capital on 9147 Capital providers withdraw after poor results or better returns elsewhere. Class StrategicCapital and funding Entities Syn 9147Owner Chief Financial OfficerInherent 12 · Medium Residual 8 · Medium Controls Effective Key controls Key risk indicator Capital commitments for next year
Scoring Inherent L3 × I4 → residual L2 × I4
Within appetite
SR-03.3 Internal model misstates capital The capital model misses new classes, fronting or the Dubai book. Class StrategicCapital and funding Entities Syn 9146 · Syn 9147Owner Head of CapitalInherent 12 · Medium Residual 8 · Medium Controls Effective Key controls Key risk indicator Open validation findings
Scoring Inherent L3 × I4 → residual L2 × I4
Within appetite
OR-06.4 Fronting arrangement breakdown A fronting agreement fails on service, regulatory standing or data. Class OperationalOutsourcing and third parties Entities Syn 9146 · Syn 9147 · DubaiOwner Chief Operating OfficerInherent 12 · Medium Residual 8 · Medium Controls Partially effective Key controls Key risk indicator Fronting SLA breaches
Scoring Inherent L3 × I4 → residual L2 × I4
Within appetite
MR-05.1 Liquidity squeeze after a major loss Claims must be paid before reinsurance recoveries arrive. Class MarketLiquidity Entities Syn 9146 · Syn 9147Owner Chief Financial OfficerInherent 10 · Medium Residual 8 · Medium Controls Effective Key controls Key risk indicator Liquid assets vs 1-in-200 cash need
Scoring Inherent L2 × I5 → residual L2 × I4
Within appetite
CR-01.2 Reinsurance programme gaps Outwards cover fails to respond as intended to a major loss. Class CounterpartyReinsurance Entities Syn 9146 · Syn 9147Owner Head of ReinsuranceInherent 10 · Medium Residual 8 · Medium Controls Effective Key controls Key risk indicator Unsigned contracts at inception
Scoring Inherent L2 × I5 → residual L2 × I4
Within appetite
SR-03.1 Insufficient capital for the plan Funds at Lloyd's fall short of the requirement after losses or growth. Class StrategicCapital and funding Entities Syn 9146 · Syn 9147Owner Chief Financial OfficerInherent 10 · Medium Residual 8 · Medium Controls Effective Key controls Key risk indicator Solvency coverage ratio
Scoring Inherent L2 × I5 → residual L2 × I4
Within appetite
CR-03.1 Fronting partner insolvency Failure of the UAE or US fronting insurer leaves premium or claims funds exposed. Class CounterpartyFronting partners Entities Syn 9146 · Syn 9147 · DubaiOwner Chief Financial OfficerInherent 8 · Medium Residual 8 · Medium Controls Partially effective Key controls Key risk indicator Fronting partner rating and balances
Scoring Inherent L2 × I4 → residual L2 × I4
Within appetite
IR-01.1 Underwriting outside appetite or authority Risks written outside the approved plan, line sizes or individual underwriter authorities. Class InsurancePremium Entities Syn 9146 · Syn 9147Owner Chief Underwriting OfficerInherent 12 · Medium Residual 6 · Low Controls Effective Key controls Key risk indicator Referrals breaching authority per month
Scoring Inherent L3 × I4 → residual L2 × I3
Within appetite
IR-03.4 Political violence accumulation Terror and unrest exposure builds up in a small number of cities. Class InsuranceCatastrophe Entities Syn 9146 · DubaiOwner Chief Underwriting OfficerInherent 12 · Medium Residual 6 · Low Controls Effective Key controls Key risk indicator PV&T aggregate by city
Scoring Inherent L3 × I4 → residual L2 × I3
Within appetite
IR-05.2 Large single-risk exposure One large loss on a big line exceeds tolerance. Class InsuranceAccumulation & aggregation Entities Syn 9146 · Syn 9147Owner Chief Underwriting OfficerInherent 12 · Medium Residual 6 · Low Controls Effective Key controls Key risk indicator Lines above guideline size
Scoring Inherent L3 × I4 → residual L2 × I3
Within appetite
SR-01.2 Business plan deviation Premium mix or rate departs materially from the Lloyd's-approved business plan. Class StrategicExecution Entities Syn 9146 · Syn 9147Owner Chief Underwriting OfficerInherent 12 · Medium Residual 6 · Low Controls Effective Key controls Key risk indicator GWP variance vs plan by class
Scoring Inherent L3 × I4 → residual L2 × I3
Within appetite
SR-04.2 Conflicts between 9146 and 9147 Risk allocation or internal reinsurance favours one syndicate's capital providers. Class StrategicGroup and intra-group Entities Syn 9146 · Syn 9147 · Managing agentOwner Head of ComplianceInherent 12 · Medium Residual 6 · Low Controls Effective Key controls Key risk indicator Conflicts logged and resolved
Scoring Inherent L3 × I4 → residual L2 × I3
Within appetite
OR-01.1 Prolonged system outage Critical systems are unavailable beyond impact tolerances. Class OperationalBusiness continuity and IT resilience Entities Managing agentOwner Chief Information OfficerInherent 12 · Medium Residual 6 · Low Controls Effective Key controls Key risk indicator Impact tolerance breaches
Scoring Inherent L3 × I4 → residual L2 × I3
Within appetite
OR-02.2 Third-party data breach A supplier leaks our or our clients' data. Class OperationalCyber Entities Managing agentOwner Chief Information Security OfficerInherent 12 · Medium Residual 6 · Low Controls Effective Key controls Key risk indicator Suppliers with overdue assessments
Scoring Inherent L3 × I4 → residual L2 × I3
Within appetite
OR-03.1 Loss of key underwriters Key underwriters leave and take relationships with them. Class OperationalPeople Entities Syn 9146 · Syn 9147Owner Head of HRInherent 12 · Medium Residual 6 · Low Controls Effective Key controls Key risk indicator Regretted leavers
Scoring Inherent L3 × I4 → residual L2 × I3
Within appetite
OR-04.1 Breach of PRA, FCA or Lloyd's requirements Rules or Lloyd's minimum standards are breached. Class OperationalRegulatory and compliance Entities Managing agent · Syn 9146 · Syn 9147Owner Head of ComplianceInherent 12 · Medium Residual 6 · Low Controls Effective Key controls Key risk indicator Open regulatory findings
Scoring Inherent L3 × I4 → residual L2 × I3
Within appetite
OR-06.5 Critical outsourced service failure A key outsourced IT or claims provider fails. Class OperationalOutsourcing and third parties Entities Managing agentOwner Chief Operating OfficerInherent 12 · Medium Residual 6 · Low Controls Effective Key controls Key risk indicator Material outsourcer SLA breaches
Scoring Inherent L3 × I4 → residual L2 × I3
Within appetite
IR-01.6 Unintended policy coverage Wordings give cover that was never priced, such as silent cyber. Class InsurancePremium Entities Syn 9146 · Syn 9147Owner Head of ProductInherent 9 · Medium Residual 6 · Low Controls Effective Key controls Key risk indicator Wording exceptions approved
Scoring Inherent L3 × I3 → residual L2 × I3
Within appetite
IR-02.2 Reserving data quality Incomplete delegated and fronted claims data distorts reserves. Class InsuranceReserving Entities Syn 9146 · Syn 9147Owner Chief ActuaryInherent 9 · Medium Residual 6 · Low Controls Effective Key controls Key risk indicator Bordereaux late or incomplete
Scoring Inherent L3 × I3 → residual L2 × I3
Within appetite
IR-04.2 Loss of coverholder agreements Key coverholder binders are not renewed or are cancelled mid-term, removing planned premium. Class InsuranceLapse Entities Syn 9146 · DubaiOwner Head of Delegated AuthorityInherent 9 · Medium Residual 6 · Low Controls Effective Key controls Key risk indicator Binder premium up for renewal in 90 days
Scoring Inherent L3 × I3 → residual L2 × I3
Within appetite
MR-01.1 Rising interest rates reduce bond values Higher rates cut the market value of the fixed income portfolio. Class MarketInterest rate Entities Syn 9146 · Syn 9147Owner Chief Financial OfficerInherent 9 · Medium Residual 6 · Low Controls Effective Key controls Key risk indicator Portfolio duration vs limit
Scoring Inherent L3 × I3 → residual L2 × I3
Within appetite
MR-01.2 Asset-liability duration mismatch Asset durations drift from long-tail casualty liabilities. Class MarketInterest rate Entities Syn 9147Owner Chief Financial OfficerInherent 9 · Medium Residual 6 · Low Controls Effective Key controls Key risk indicator Duration gap
Scoring Inherent L3 × I3 → residual L2 × I3
Within appetite
MR-03.1 Credit spread widening Wider corporate bond spreads reduce asset values. Class MarketSpread Entities Syn 9146 · Syn 9147Owner Chief Financial OfficerInherent 9 · Medium Residual 6 · Low Controls Effective Key controls Key risk indicator Average portfolio credit rating
Scoring Inherent L3 × I3 → residual L2 × I3
Within appetite
MR-04.1 Currency mismatch losses Assets and liabilities in USD, EUR and AED are not matched. Class MarketCurrency Entities Syn 9146 · Syn 9147Owner Chief Financial OfficerInherent 9 · Medium Residual 6 · Low Controls Effective Key controls Key risk indicator Net open FX position
Scoring Inherent L3 × I3 → residual L2 × I3
Within appetite
CR-02.1 Broker concentration A handful of brokers controls a large share of premium. Class CounterpartyDistribution Entities Syn 9146 · Syn 9147Owner Chief Underwriting OfficerInherent 9 · Medium Residual 6 · Low Controls Effective Key controls Key risk indicator Share of GWP from top three brokers
Scoring Inherent L3 × I3 → residual L3 × I2
Within appetite
CR-02.3 Premium credit control failure Premium is not collected on time from brokers and coverholders. Class CounterpartyDistribution Entities Syn 9146 · Syn 9147Owner Chief Financial OfficerInherent 9 · Medium Residual 6 · Low Controls Partially effective Key controls Key risk indicator Premium debt over 90 days
Scoring Inherent L3 × I3 → residual L3 × I2
Within appetite
OR-04.2 DFSA requirements not met in Dubai The Dubai entity falls short of DFSA rules. Class OperationalRegulatory and compliance Entities DubaiOwner Dubai Compliance OfficerInherent 9 · Medium Residual 6 · Low Controls Effective Key controls Key risk indicator DFSA returns submitted late
Scoring Inherent L3 × I3 → residual L2 × I3
Within appetite
OR-04.5 Lloyd's and Solvency II reporting errors Regulatory returns are late or inaccurate. Class OperationalRegulatory and compliance Entities Syn 9146 · Syn 9147Owner Chief Financial OfficerInherent 9 · Medium Residual 6 · Low Controls Effective Key controls Key risk indicator Returns resubmitted
Scoring Inherent L3 × I3 → residual L2 × I3
Within appetite
OR-05.3 Claims leakage Money lost through weak adjusting, fraud or missed recoveries. Class OperationalProcess Entities Syn 9146 · Syn 9147Owner Head of ClaimsInherent 9 · Medium Residual 6 · Low Controls Effective Key controls Key risk indicator Leakage found in file reviews
Scoring Inherent L3 × I3 → residual L2 × I3
Within appetite
OR-09.1 Poor customer outcomes Policyholders receive unfair treatment or poor claims service. Class OperationalConduct Entities Syn 9146 · Syn 9147Owner Head of ComplianceInherent 9 · Medium Residual 6 · Low Controls Effective Key controls Key risk indicator Complaints upheld
Scoring Inherent L3 × I3 → residual L2 × I3
Within appetite
IR-02.3 Climate litigation Insureds are sued for climate-related harm under liability policies. Class InsuranceReserving Entities Syn 9147Owner Chief Underwriting OfficerInherent 8 · Medium Residual 6 · Low Controls Effective Key controls Key risk indicator Climate-related claims notified
Scoring Inherent L2 × I4 → residual L2 × I3
Within appetite
CR-01.4 Group reinsurer support withdrawn The group reinsurer cannot renew the stop-loss. Class CounterpartyReinsurance Entities Syn 9146Owner Chief Executive OfficerInherent 8 · Medium Residual 6 · Low Controls Effective Key controls Key risk indicator Group reinsurer capital ratio
Scoring Inherent L2 × I4 → residual L2 × I3
Within appetite
SR-04.1 Intra-group reinsurance not at arm's length The stop-loss or inter-syndicate quota share favours one party. Class StrategicGroup and intra-group Entities Syn 9146 · Syn 9147 · Managing agentOwner Chief Financial OfficerInherent 8 · Medium Residual 6 · Low Controls Effective Key controls Key risk indicator Intra-group terms reviewed
Scoring Inherent L2 × I4 → residual L2 × I3
Within appetite
SR-06.2 Culture misaligned with conduct expectations Behaviours fall short of Lloyd's and FCA culture expectations. Class StrategicGovernance and reputation Entities Managing agentOwner Chief Executive OfficerInherent 8 · Medium Residual 6 · Low Controls Effective Key controls Key risk indicator Speak-up cases
Scoring Inherent L2 × I4 → residual L2 × I3
Within appetite
CR-03.2 Fronting partner downgrade A rating downgrade makes a fronting insurer's paper unacceptable to clients. Class CounterpartyFronting partners Entities Syn 9146 · Syn 9147 · DubaiOwner Chief Financial OfficerInherent 6 · Low Residual 6 · Low Controls Partially effective Key controls Key risk indicator Fronting partner ratings
Scoring Inherent L2 × I3 → residual L2 × I3
Within appetite
OR-04.4 Premium tax non-compliance Premium taxes across territories, including UAE VAT, are miscalculated or unpaid. Class OperationalRegulatory and compliance Entities Syn 9146 · Syn 9147 · DubaiOwner Head of TaxInherent 9 · Medium Residual 4 · Low Controls Effective Key controls Key risk indicator Tax payments late or adjusted
Scoring Inherent L3 × I3 → residual L2 × I2
Within appetite
OR-05.4 Inaccurate risk and board MI Management information misleads decision-makers. Class OperationalProcess Entities Managing agentOwner Chief Risk OfficerInherent 9 · Medium Residual 4 · Low Controls Effective Key controls Key risk indicator MI errors identified
Scoring Inherent L3 × I3 → residual L2 × I2
Within appetite
CR-01.1 Reinsurer default A reinsurer fails to pay recoveries. Class CounterpartyReinsurance Entities Syn 9146 · Syn 9147Owner Head of ReinsuranceInherent 8 · Medium Residual 4 · Low Controls Effective Key controls Key risk indicator Recoverables from reinsurers below A rating
Scoring Inherent L2 × I4 → residual L1 × I4
Within appetite
SR-06.1 Ineffective board oversight The board and committees fail to challenge management effectively. Class StrategicGovernance and reputation Entities Managing agentOwner Company SecretaryInherent 8 · Medium Residual 4 · Low Controls Effective Key controls Key risk indicator Board actions overdue
Scoring Inherent L2 × I4 → residual L1 × I4
Within appetite
OR-04.3 Licensing breaches Business is written in territories where we are not licensed. Class OperationalRegulatory and compliance Entities Syn 9146 · Syn 9147Owner Head of ComplianceInherent 8 · Medium Residual 4 · Low Controls Effective Key controls Key risk indicator Licensing exceptions
Scoring Inherent L2 × I4 → residual L1 × I4
Within appetite
OR-05.1 Material misstatement Financial statements contain a material error. Class OperationalProcess Entities Managing agent · Syn 9146 · Syn 9147Owner Chief Financial OfficerInherent 8 · Medium Residual 4 · Low Controls Effective Key controls Key risk indicator Audit adjustments
Scoring Inherent L2 × I4 → residual L1 × I4
Within appetite
OR-07.2 Bribery and corruption Staff or intermediaries offer or accept bribes. Class OperationalFinancial crime Entities Dubai · Managing agentOwner Money Laundering Reporting OfficerInherent 8 · Medium Residual 4 · Low Controls Effective Key controls Key risk indicator Due diligence overdue
Scoring Inherent L2 × I4 → residual L1 × I4
Within appetite
IR-04.1 Early termination of multi-year contracts Multi-year policies and long-term agreements are cancelled early, removing expected profit. Class InsuranceLapse Entities Syn 9146 · Syn 9147Owner Chief Underwriting OfficerInherent 6 · Low Residual 4 · Low Controls Effective Key controls Key risk indicator Retention rate by class
Scoring Inherent L2 × I3 → residual L2 × I2
Within appetite
CR-02.2 Coverholder and broker credit Premium held by intermediaries is lost if they fail. Class CounterpartyDistribution Entities Syn 9146 · Syn 9147Owner Chief Financial OfficerInherent 6 · Low Residual 4 · Low Controls Effective Key controls Key risk indicator Balances held by coverholders
Scoring Inherent L3 × I2 → residual L2 × I2
Within appetite
SR-01.5 Expense overrun Operating costs exceed budget as the business grows. Class StrategicExecution Entities Managing agentOwner Chief Financial OfficerInherent 6 · Low Residual 4 · Low Controls Effective Key controls Key risk indicator Expense ratio vs plan
Scoring Inherent L3 × I2 → residual L2 × I2
Within appetite
SR-06.3 Reputational damage from poor communication Mishandled messages damage trust with brokers, regulators or capital providers. Class StrategicGovernance and reputation Entities Managing agentOwner Chief Executive OfficerInherent 6 · Low Residual 4 · Low Controls Effective Key controls Key risk indicator Negative media mentions
Scoring Inherent L2 × I3 → residual L2 × I2
Within appetite
SR-07.1 ESG commitments not met Public ESG commitments are missed. Class StrategicESG and climate Entities Managing agentOwner Chief Executive OfficerInherent 6 · Low Residual 4 · Low Controls Effective Key controls Key risk indicator Progress against ESG targets
Scoring Inherent L2 × I3 → residual L2 × I2
Within appetite
OR-09.2 Products not delivering fair value Products fail Consumer Duty fair value assessments. Class OperationalConduct Entities Syn 9146 · Managing agentOwner Head of ComplianceInherent 6 · Low Residual 4 · Low Controls Effective Key controls Key risk indicator Products with open value actions
Scoring Inherent L2 × I3 → residual L2 × I2
Within appetite
MR-02.1 Equity market fall A fall in markets reduces the value of the small equity allocation. Class MarketEquity Entities Syn 9146 · Syn 9147Owner Chief Financial OfficerInherent 4 · Low Residual 4 · Low Controls Effective Key controls Key risk indicator Equity allocation vs cap
Scoring Inherent L2 × I2 → residual L2 × I2
Within appetite
MR-05.2 Trapped cash in Dubai Cash builds up in the DIFC entity beyond what is needed locally. Class MarketLiquidity Entities DubaiOwner Chief Financial OfficerInherent 4 · Low Residual 4 · Low Controls Effective Key controls Key risk indicator Cash held above buffer
Scoring Inherent L2 × I2 → residual L2 × I2
Within appetite
OR-02.3 Privileged access misuse Staff misuse elevated system access. Class OperationalCyber Entities Managing agentOwner Chief Information Security OfficerInherent 8 · Medium Residual 3 · Low Controls Effective Key controls Key risk indicator Leavers with active access
Scoring Inherent L2 × I4 → residual L1 × I3
Within appetite
OR-05.2 Payment fraud or error Funds are paid to the wrong party through fraud or mistake. Class OperationalProcess Entities Managing agentOwner Chief Financial OfficerInherent 8 · Medium Residual 3 · Low Controls Effective Key controls Key risk indicator Payment exceptions
Scoring Inherent L2 × I4 → residual L1 × I3
Within appetite
OR-01.2 Loss of office access London or Dubai offices become unusable for an extended period. Class OperationalBusiness continuity and IT resilience Entities Managing agent · DubaiOwner Chief Operating OfficerInherent 6 · Low Residual 3 · Low Controls Effective Key controls Key risk indicator BCP tests completed on schedule
Scoring Inherent L2 × I3 → residual L1 × I3
Within appetite
CR-04.1 Bank or custodian failure A bank or custodian holding our cash or assets fails. Class CounterpartyBanks and custodians Entities Managing agent · Syn 9146 · Syn 9147Owner Chief Financial OfficerInherent 4 · Low Residual 3 · Low Controls Effective Key controls Key risk indicator Cash with a single bank vs limit
Scoring Inherent L1 × I4 → residual L1 × I3
Within appetite
MR-04.2 AED peg risk A change to the dirham's dollar peg hits Dubai and fronted balances. Class MarketCurrency Entities Dubai · Syn 9146Owner Chief Financial OfficerInherent 3 · Low Residual 3 · Low Controls Effective Key controls Key risk indicator Net AED exposure
Scoring Inherent L1 × I3 → residual L1 × I3
Within appetite
Sorted by residual score, highest first · likelihood × impact on 1 to 5 scales: high 15+, medium 8 to 12, low up to 6 · select a risk for its controls and key risk indicator.
What it tells us
What it tells us this quarter
16 Both high risks score 16 out of 25, and both rely on controls rated ineffective.
2 Both sit with third parties in the register: a coverholder (OR-06.1) and the UAE fronting partner (OR-06.2).
12 Next come three medium risks scoring 12: US social inflation, long-tail casualty reserves and systemic cyber.
What we did
What we did about it
Actions on the two high risks, from Halden's action log.
ACT-038
Remediate Ridgeway Underwriting breaches (INC-031)
Owner Head of Delegated Authority Policy (approved by) Delegated authority · Underwriting committee Due 31 Oct 2026 ACT-035
Clear the coverholder audit backlog (6 overdue)
Owner Head of Delegated Authority Policy (approved by) Delegated authority · Underwriting committee Due 30 Sep 2026 ⚠ overdue ACT-029
Agree claims service levels with the UAE fronting partner (INC-028)
Owner Head of Claims Policy (approved by) Claims management · Underwriting committee Due 31 Oct 2026 Actions are listed under the policy they sit in. The action log does not record a deciding committee.
Sources
Where the numbers come from
Risks, owners and scores come from the register itself. Control ratings come from second-line control testing.
Board data risk register at 30 Sep 2026 (79 risks)
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