The need to reduce fixed operating costs and the demand for digital channels and services are both driving the move to cloud in banking ... and both those forces have accelerated this year. As a result, we are seeing some significant developments among major banks.

These changes require significant work to adapt the control environment to suit the new operating model - both risk management and compliance require changes to provide the same level of assurance with data and workloads in the cloud. And Boards need to become comfortable with a different risk appetite profile, with greater reliance on software based controls rather than physical controls.

To achieve this, it is essential that top management do not regard the move to cloud simply as a change in the infrastructure - but rather, as a fundamental change of business model, requiring an end-to-end review of risk management, from risk identification down to monitoring and controls.