CBUAE System Migration Assurance Services

CBUAE System Migration Assurance Requirements

For UAE Licensed Financial Institutions (LFIs), major system implementations, replacements, upgrades, and migrations may be subject to specific Central Bank of the UAE (CBUAE) assurance and change-management requirements.

Where a change is material to Critical Operations or may materially affect customers, CBUAE requirements include:

  • Thorough testing before implementation
  • Appropriate review and approval of testing results
  • Recovery and rollback planning
  • Parallel operation of old and new ICT systems, where applicable
  • Independent assurance by an external expert at key stages
  • Senior Management review and endorsement of the independent assurance report
  • Submission of the external expert report to CBUAE at least 30 calendar days before the proposed implementation
  • Obtaining CBUAE written no-objection before implementation

For core system migration projects, the provided CBUAE requirements also expect the independent external implementation assurance provider to be engaged from project initiation and provide assurance throughout the project lifecycle.

Assurance Across the Complete Migration Lifecycle

MAST Consulting can provide independent assurance across:

Analysis & Selection → Strategy & Planning → Implementation → Data Migration → Testing → Cybersecurity Readiness → Go-Live → Post-Go-Live

The assurance review evaluates project governance, system and implementation partner selection, project planning, vendor management, risk and issue management, solution design, data migration, testing, defect management, training, cutover, and operational readiness.

Before go-live, assurance can also validate the status of testing, data migration, defects, risks and issues, infrastructure readiness, operational preparedness, and cybersecurity testing. The provided CBUAE requirements specifically require confirmation that vulnerability assessment and penetration testing have been completed against the production environment and that high and critical findings have been remediated.

How MAST Consulting Can Support

MAST Consulting acts as an independent System Migration Assurance partner, providing objective assessment throughout the project lifecycle and helping management identify and address risks before critical migration decisions and go-live.

Our services can support LFIs with:

  • Independent implementation and migration assurance
  • CBUAE-aligned assurance assessments
  • Project governance and risk reviews
  • Data migration assurance
  • Testing and defect management assurance
  • Cybersecurity and VAPT readiness review
  • Go-live readiness assessment
  • Independent assurance reporting
  • Board and Senior Management reporting
  • Findings and remediation tracking
  • Post-go-live assurance
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    Frequently Asked Questions (FAQ)

    What is System Migration Assurance?
    System Migration Assurance is an independent review of a system implementation, upgrade, or migration to assess project risks, governance, data migration, testing, cybersecurity, operational readiness, and go-live preparedness.
    Does CBUAE require independent assurance for core system migration?
    The provided CBUAE requirements state that an independent external implementation assurance provider must be engaged for a new core system implementation or migration. The provider is expected to be engaged from project initiation and perform assurance activities throughout the project lifecycle.
    When should the assurance provider be engaged?
    The assurance provider should be engaged at the initiation of the project, rather than only before go-live, so assurance can be performed throughout the project.
    What areas are covered by System Migration Assurance?
    The CBUAE requirements identify four key stages: Analysis & Selection, Strategy & Planning, Implementation, and Go-Live. Reviews can cover system and vendor selection, governance, project planning, data migration, testing, defect management, training, cutover, and post-go-live activities.
    Is cybersecurity testing required before go-live?
    The provided requirements call for confirmation that vulnerability assessment and penetration testing have been completed against the production environment, with high and critical findings remediated.
    Does the assurance cover data migration and testing?
    Yes. Data migration, testing strategy, UAT, performance and regression testing, and defect management are specifically included within the assurance areas identified by CBUAE.
    Are assurance reports required to be submitted to CBUAE?
    The provided requirements state that internal and external assurance reports must be presented in full to the LFI's Board and shared with the Central Bank throughout the project lifecycle.
    What should be confirmed before go-live?
    Key areas include completion of testing and data migration, closure of relevant defects, risks and issues, VAPT remediation, infrastructure readiness, operational preparedness, cutover planning, and post-go-live support.
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