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Article July 22, 2025

From Compliance to Combat Mode: Why Liquidity Planning Must Get Real

From Compliance to Combat Mode: Why Liquidity Planning Must Get Real

Henry Kwan, Senior Vice President and Deputy Treasurer, East West BankLinkedIn profile for Henry Kwan

Banks are moving beyond regulatory checkboxes to actively simulate liquidity crises, uncovering gaps in contingency funding plans and redefining resilience.

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In early 2023, the collapse of Silicon Valley Bank reignited a long-simmering conversation about liquidity risk and forced a personal reckoning for many of us in treasury roles.

The assumptions once taken for granted proved to be fragile under pressure. What followed was a comprehensive reassessment of liquidity frameworks across functions—culminating in the development of a full-scale CFP tabletop exercise. This evolution reflects a growing recognition that proactive, enterprise-wide simulations are essential for building true crisis readiness. This wasn’t just a check-the-box exercise to placate regulators. It was a turning point.

The objective was to simulate the pace and complexity of a real liquidity shock—not to pass a test, but to identify possible points of failure. The exercise tested coordination across geographies, time zones, and business functions. It can surface friction points in communication, gaps in contact protocols, and misalignments in escalating timing. Just as importantly, it can highlight the resilience of teams capable of adapting under pressure.

For institutions operating internationally, crisis response is never just local. Cross-border execution adds a layer of complexity that traditional CFPs rarely address.

It became clear that a contingency plan cannot sit in a drawer. It has to live, evolve, and be tested – again and again – until it holds under fire.

One of the most sobering industry lessons in the wake of SVB was how few banks had collateral pre-positioned when they needed it most. Access to liquidity lines is not enough. Operational readiness – knowing exactly how and when to tap those lines, and who pulls the trigger – is non-negotiable.

The speed of decision-making must match the speed of the crisis. This includes being operationally prepared to navigate funding channels that, under market liquidity stress, can become significantly more difficult to access due to heightened demand, tighter execution windows, and constrained market liquidity."

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