Establishing a BCBS 239 Compliance Program at a Global Investment Bank

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Sagence’s  experience in regulatory compliance assisted an investment bank in designing, developing and managing initiatives to ensure BCBS 239 compliance.


Our client, a leading global investment bank, private bank and wealth manager with a presence in over 150 countries formed a Global Chief Data Office (GCDO) with a mandate to coordinate key data activities across all of its divisions.  The initial focus of the GCDO was to comply with the data management requirements that are an integral component of the BCBS 239 regulation.  Sagence was engaged to develop and manage key components of the Bank’s BCBS 239 compliance initiatives.


The Sagence team assessed existing data policies for applicability to BCBS 239 principles. We were then able to advise and provide oversight on appropriate changes required to be compliant. Specifically, for this client the Sagence team:

  • Developed data governance standards, frameworks and operating models covering key capabilities including business glossary, data lineage, data quality and data tooling applying industry best practices and BCBS 239 requirements.
  • Created an enterprise-wide roadmap to manage initiatives to improve data quality maturity levels.
  • Conducted and communicated regular quantitative and qualitative reviews of divisional adherence to BCBS 239.
  • Setup an enterprise-wide PMO governance model (organization design, resource planning, program scope, divisional and enterprise project plans, reporting requirements, etc.).
  • Developed standards to assess divisional and functional conformity to enterprise-wide data governance policy.
  • Formulated a framework for the bank to transition from project work streams to Business as Usual (BaU) processes.


The Bank was able to rapidly develop its GCDO capabilities providing the foundation to address future data issues and better leverage its data assets. The data governance policies, standards and frameworks were successfully communicated and adopted across the entire enterprise. The GCDO PMO implemented provided the necessary structure and guidance to successfully complete major regulatory initiatives.