Operational Resilience in 2025: A Cross-Jurisdictional View

Global regulators are converging on operational resilience but the paths to compliance vary. Here’s what financial institutions need to know now.

2025 marks a turning point for operational resilience frameworks across global jurisdictions. As regulators intensify expectations beyond traditional business continuity planning, financial institutions must align on new playbooks that account for cross-border complexity, third-party dependencies, and digital disruptions.

Who it’s for:
Chief Risk Officers, Business Continuity Heads, Regional Risk Teams, and Regulatory Affairs Leaders.

⚠️ The Challenge

The term “operational resilience” has gone from niche to mandatory. But inconsistent frameworks and timelines across regulatory bodies have created confusion, including:

  • Fragmented definitions of “important business services” (IBS) 
  • Divergent testing thresholds and timelines 
  • Inconsistent treatment of third-party and cloud dependencies 
  • Lack of clarity around impact tolerances and metrics 
  • Vague expectations around senior management accountability

The result? Global firms struggle to scale resilience programs that satisfy overlapping mandates from the FCA, OCC, APRA, and more.

5 Pillars of Cross-Jurisdictional Resilience

Use this Wyman-built framework to anchor a scalable, compliance-aligned program:

IBS Mapping at Global Scale

Standardize taxonomy across regions; map upstream/downstream dependencies.

Impact Tolerances

Define, quantify, and align tolerances with risk appetite statements.

Scenario Testing

Conduct diverse tests: cyber, vendor outage, geopolitical shock.

Governance & Accountability

Formalize senior manager responsibility and board visibility.

Regulatory Traceability

Maintain documentation mapped to jurisdictional expectations.

✅ Tangible Takeaways

  • Create a global resilience heat map showing jurisdictional gaps and overlaps.

  • Build a single IBS inventory tagged to jurisdictional needs, not local silos.

  • Invest in a central traceability layer for control design, testing, and documentation.

  • Formalize an executive-level resilience playbook with board-facing updates.

Don’t wait regulatory harmonization won’t arrive in time. Design for variation, not uniformity.

🎤 Closing POV

At Wyman Advisory, we’ve helped global financial institutions align resilience strategies across the U.S., U.K., EU, APAC, and beyond. Our resilience operating model balances compliance readiness with operational pragmatism ensuring your firm can pass any test, in any region.

Whether you’re facing FCA PS21/3, OCC guidance, or MAS expectations resilience isn’t optional. It’s your license to operate.

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