Suspicions of financial fraud may be triggered externally or internally. External triggers include negative market news such as short seller reports and/or industry rumors alleging the customer of financial misrepresentation. Such accusations, regardless of validity, have the potential to create liquidity stress for a company which, if not carefully managed, could lead to credit loss for the Bank. It is therefore important for Business and Risk to be able to respond swiftly and collaboratively against such external threats, especially where they are considered to be material and credible. Suspicions of fraud may also arise from internal observation of the customer’s activities (e.g. questionable transactions detected by bank systems), from our normal KYC/due diligence or as material escalations from the Fraud Analytics Model, which is currently under development by ASP CMB Analytics.