Diagrams and notesFour Records and a Fifth That Hold an Insider Program Together
Each either exists or it does not: an initial test of whether the functions have a meeting point, not proof that the program works.
27 JULY 2026 | DIAGRAM
An insider risk management program has a point where its parts are supposed to meet. That point is not a meeting or a mandate. In the operating model I use, it is made of specific records, each of which either exists or does not: an initial test of whether the functions have a meeting point at all, not proof that the program works.
Under European conditions each of the four carries the applicable requirements and safeguards, and their sum has to be declared as one account. That account is the fifth record. All five need updating as the program changes, and the fifth most often, because it depends on the other four.
The full argument is in What Holds an Insider Program Together.