Do you have experience with multi-entity implementations?

Yes - experience includes coordinating DORA programs across multiple EU jurisdictions with different supervisory regimes. Focus is on harmonization while respecting local requirements.

How do you handle different supervisory expectations?

Structured approach: map requirements per jurisdiction, identify common baseline, document deviations with rationale. Evidence framework designed for multi-regulator audit.

What about non-EU entities?

DORA applies to EU entities and third-country branches. I help structure third-country considerations and information-sharing arrangements within regulatory constraints.

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EU COMPLIANCE

DORA Implementation: Cross-Border Compliance for EU Financial Institutions

DORA requires consistent operational resilience across all EU entities. I bring program management discipline to multi-jurisdictional DORA implementations - with evidence frameworks that satisfy EBA, ECB, and local supervisors.

EU-Wide Operational Resilience

The Digital Operational Resilience Act creates a unified framework for ICT risk management across the European Union. For international financial groups, this means:

Harmonized ICT Risk: Consistent risk management framework across all EU entities
Cross-Border Testing: Coordinated resilience testing including TLPT for systemically important institutions
Third-Party Oversight: Group-level management of critical ICT service providers
Unified Incident Reporting: Consolidated reporting channels meeting multiple supervisory requirements

Deliverables: EU-Wide Evidence Framework

Multi-entity DORA implementation roadmap with jurisdictional mapping

Unified evidence pack: decision log, risk register, test evidence, vendor controls

Third-party control matrix for cross-border providers

Stakeholder reporting (board, supervisors, group functions)

Audit-ready documentation meeting EBA and local supervisor expectations

Structured evidence framework designed for multi-regulator environments - from EBA to national competent authorities.

Cross-Border Third-Party Risk

DORA's Critical ICT Third-Party Provider (CTPP) regime requires group-level oversight. I support with:

Group-level provider mapping and criticality assessment
Control harmonization across jurisdictions
Vendor governance: consolidated reporting and exit planning
Preparation for ESA oversight of designated CTPPs

Multi-Entity Resilience Testing

DORA mandates coordinated testing across connected entities. I support with planning and evidence coordination:

Group-wide test strategy with local entity requirements
Cross-border scenario coordination with providers
Consolidated evidence management and remediation tracking
TLPT preparation for systemically important entities

Multi-Jurisdictional Coordination

DORA implementation for international groups requires alignment across functions and supervisors. I coordinate with:

Group Compliance and local entity functions
Multiple supervisory relationships (home/host)
Legal interpretation alignment across jurisdictions

Project contexts are anonymized. Roles and results are truthful; details available under NDA.

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Last updated: January 2026