Experience ESG & GRC Intelligence in Action
See how SustainGRC replaces fragmented GRC and sustainability tools with one audit-grade source of truth.
BANKING & FINANCIAL SERVICES
Leading Gulf Bank Closes Three Regulatory Gaps in 6 Months
How a $45bn commercial bank replaced seven disconnected tools with one governed platform — and satisfied central bank supervisors in under 6 months.
3
Regulatory gaps closed
2
months to first value
7
Legacy Systems Replaced
Executive Summary
A leading commercial bank in the Middle East, with operations across six Gulf states and over $45 billion in assets under management, faced mounting pressure from regulators, investors, and the board to demonstrate credible governance over non-financial data — particularly climate risk integration into core banking operations.
The bank selected SustainGRC to replace fragmented ESG tools, disconnected GRC platforms, and manual audit processes with a single governed source of truth. Within six months of deployment, the bank achieved audit-ready non-financial data across all reporting entities — and satisfied central bank supervisors on three specific requirements it could not previously evidence.
The catalyst: Three questions that required a new approach
Like many financial institutions in the region, the bank had accumulated multiple point solutions over several years. Each solved a narrow problem. None talked to each other. And critically, none could provide the evidence trails that regulators were now demanding.
Regulatory pressure intensified when central bank supervisors — aligning with Basel Committee principles and the region's emerging sustainable finance frameworks — requested evidence across three specific areas:
| Regulatory requirement | What supervisors asked for |
|---|---|
| 1. Financed emissions lineage | Auditable trail from borrower-level Scope 1, 2, and 3 data through portfolio aggregation to disclosure — with validation controls at each stage |
| 2. Climate risk in credit decisioning | Documented controls showing how transition and physical risk factors fed into lending approvals, portfolio monitoring, and collateral valuations |
| 3. Control ownership for external assurance | Clear accountability and evidence trails to support independent verification — as required under emerging ISSB limited assurance requirements |
The bank's existing tools could not deliver on any of these.
Seven tools, zero integration
| Existing tool | Gap it created |
|---|---|
| Standalone carbon accounting (Scope 1 & 2 only) | No link to lending portfolio — couldn't calculate financed emissions |
| Spreadsheet-based ESG data collection | No validation — 23 subsidiaries submitting unverified data with no audit trail |
| Legacy GRC platform (focused on IT controls) | Siloed from climate data — risk register blind to transition risk |
| Manual internal audit workflows | No evidence capture — 6+ weeks to respond to regulator document requests |
| Separate supplier risk questionnaires | No linkage to Scope 3 — supply chain outside core governance |
"We had twenty years of infrastructure for financial data, but zero years for non-financial data. Every audit became a data archaeology exercise."
— Chief Audit Executive
Why SustainGRC: Infrastructure, Not Another Tool
After evaluating multiple vendors — including established ESG platforms and GRC suites — the bank selected SustainGRC based on a fundamental differentiator: SustainGRC is governance infrastructure that embeds trust at the data layer, not a reporting tool that assumes data integrity downstream.
Key Selection Criteria
| REQUIREMENT | SUSTAINGRC CAPABILITY |
|---|---|
| Data integrity at source | Real-time validation engine with business rules before data enters the system |
| End-to-end audit trail | Complete lineage from source document to published disclosure — every transformation logged |
| Multi-framework support | Single data capture supports ISSB, GRI, SASB, and central bank requirements simultaneously |
| Evidence for assurance | Complete audit trail with data lineage, timestamps, and control evidence |
| ERM integration | Climate risk indicators integrated with enterprise risk framework |
| Supply chain governance | Integrated third-party risk and Scope 3 due diligence within core platform |
Implementation: Governed from Day One
SustainGRC deployed a phased implementation over six months, prioritising the modules that would deliver immediate regulatory value while building the foundation for enterprise-wide governance. Each phase was designed to close one of the three regulatory gaps.
Phase 1: Foundation (Months 1–2)
- Entity structure mapping across 23 subsidiaries and 6 jurisdictions
- Data governance policies and validation rules configured
- Control ownership assigned with clear accountability matrix
- Enterprise risk register migrated from legacy GRC system
Regulatory gap closed: Control ownership for external assurance — clear accountability established across all entities
Phase 2: Core modules (Months 2–4)
- ESG data collection and validation for GCC unified disclosures, ISSB, GRI, and central bank requirements
- Scope 1, 2, and 3 emissions calculation with borrower-level data integration
- Internal audit planning and execution module deployed
- Climate risk indicators integrated with enterprise risk framework
Regulatory gap closed:Financed emissions lineage — complete trail from borrower data to portfolio disclosure
Phase 3: Optimisation (Months 4–6)
- Supply chain governance module for 200+ key vendors
- Board reporting dashboards with drill-down to source evidence
- Climate risk scores embedded in credit workflow and portfolio monitoring
- External assurance preparation and document package automation
Regulatory gap closed: Climate risk in credit decisioning — transition risk integrated into lending approvals
Results: The three questions answered
Six months after go-live, central bank supervisors returned.
| Supervisory question | Bank's response |
|---|---|
| Financed emissions lineage | Complete Scope 1, 2, and 3 data across 23 subsidiaries — source to disclosure in one auditable trail with validation at each stage |
| Climate risk in credit | Transition risk scores embedded in lending workflow, with documented controls tested quarterly and linked to portfolio monitoring |
| Assurance-ready evidence | First external limited assurance engagement completed in 3 weeks — previously estimated at 3+ months |
Operational Impact
- Seven legacy tools decommissioned, reducing annual software costs and eliminating reconciliation overhead
- First-ever external assurance opinion on sustainability data achieved within 6 months
- Climate risk metrics now integrated with enterprise risk appetite framework, satisfying central bank expectations
- Board reporting time reduced from 3 weeks to 3 days with confidence in underlying data
"For the first time, we can stand behind our non-financial data with the same confidence we have in our financial statements. SustainGRC gave us infrastructure we should have built years ago."
— Group Chief Risk Officer
About SustainGRC
SustainGRC is governance and sustainability intelligence infrastructure. We ensure non-financial data — across sustainability, risk, audit, and supply chains — is accurate, traceable, and auditable before it gets transformed for reporting or decisions.
Our platform ensures data integrity across Enterprise Risk Management, Internal Audit, Compliance, Sustainability, and Supply Chain. Built on AI-native technology, SustainGRC delivers real-time multi-entity validation, evidence capture, and decision intelligence for organisations managing complex portfolios.
