Author : Mayara Zenati

At Nubank, we believe the most meaningful problems for customers and for the business rarely come with ready-made answers.

That is why we challenge the status quo: not to innovate for innovation’s sake, but to remove complexity and build solutions that make important decisions simpler, faster and better.

This mindset also shapes how we are rethinking non-financial risk (NFR).

A service outage, an operational failure, a conduct issue, a critical third-party dependency or a regulatory change may appear to be very different problems. They have different owners, controls and governance forums. But they all lead to one essential question:

What is the real exposure this risk may create for customers, business resilience and Nubank?

To help answer it, we are building NFR Brain: a platform that brings together data, modelling and expert judgement to turn fragmented risk signals into a comparable, actionable view that can inform business decisions.

Challenging the status quo means rethinking risk

In many organizations, non-financial risks are still discussed primarily through qualitative ratings: low, medium or high.

Those categories can be useful, but they do not always support a decision. When leaders need to compare an operational failure, a rise in customer complaints and a critical supplier dependency, which one should come first? Where would a mitigation reduce the most exposure? Which change might be creating a risk that is not visible yet?

Without a common language, prioritization can be shaped by the most recent incident, the loudest problem or the view of whoever is in the room.

NFR Brain is designed to challenge that logic.

Rather than treating risk as an isolated activity or a report produced at the end of a process, we are working to embed it in the decisions that shape products, customer experiences and operations. It is an ambitious and still uncommon approach: using data and models not to automate judgement, but to make judgement more consistent, transparent and useful.

This is directly connected to one of Nubank’s values: we are hungry and challenge the status quo. If the traditional way of managing risk does not provide enough clarity to support better decisions, our response is not to accept that limitation. It is to build a better way to understand the problem.

Because “non-financial” describes the source of a risk, not its consequences.

A technology failure can create direct losses, recovery and compensation costs, while also affecting customer experience and trust. Friction in a customer journey can increase contacts and complaints and, over time, reduce engagement. A control gap can lead to remediation and additional investment in resilience.

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A common view, without oversimplifying complexity

NFR Brain connects four dimensions of exposure:

  • financial impact, such as operational losses, remediation costs and recoveries;
  • customer impact, considering service criticality, the duration of a disruption and evidence from customer behaviour and satisfaction;
  • reputational impact, using trust signals and trends that may reveal deterioration before it becomes harder to reverse;
  • regulatory impact, including requirements, control gaps and remediation history.

The goal is not to pretend that these dimensions are identical or to reduce complex decisions to a single number. It is to make the relationship between them visible — including the assumptions and uncertainty behind every estimate.

That reflects another core Nubank value: we want our customers to love us fanatically. Risk management is not separate from the customer experience. It is one of the ways we protect it: by understanding where failures can create friction, harm or loss of trust, and acting before they become larger problems.

Data and models in service of judgement

To estimate financial exposure, we use frequency and severity modelling. This helps us understand not only how much an event cost in the past, but also how often similar events may occur and which severe, less likely scenarios need to be considered.

Simulations let us explore different plausible combinations of events and impacts. Similarity models can help identify relevant precedents when a new incident or significant change arises, considering characteristics such as the affected process, product, duration, root cause and control environment.

But models do not replace people.

A crucial part of the work is deciding where modelling helps and where it must be challenged. Data can contain gaps, biases or correlations that are not immediately obvious. A simple-looking indicator can distort a prioritization if it is not calibrated carefully.

That is why we are building NFR Brain with clear principles: validate estimates against data the model has not seen, compare results with simple benchmarks, make uncertainty visible and keep experts close to the decisions.

We are not building a machine that “decides risk.” We are building tools that help people ask better questions and make decisions with stronger evidence.

This is also an expression of how we build strong and diverse teams. The best answers to complex risk problems do not come from one discipline alone. They emerge when different perspectives — data, engineering, product, operations, customer experience, finance, compliance and risk — challenge one another and build together.

Ownership to build what does not yet exist

Building NFR Brain takes more than a strong model. It requires connecting risks to the processes they affect, the controls that mitigate them, the incidents that reveal them and the impacts they may create.

That only works when people across disciplines take ownership of the problem together.

This is where another Nubank value comes to life: we think and act like owners, not renters. We do not wait for another team to hand us innovation. We co-create it, test hypotheses, recognize limitations and iterate until the solution is genuinely useful for the people making decisions.

We are also deliberate about where we start. It is better to build a few dimensions grounded in reliable internal data than to create a broad but fragile view based on assumptions. It is better to make uncertainty explicit than to hide it behind a precise-looking metric.

That combination of ambition and responsibility matters. It is how we build something that can scale without losing trust.

Smart efficiency in risk decisions

The value of a platform like NFR Brain becomes tangible when it reaches the decisions that shape the business.

In a product launch, it can mean assessing not only whether required controls are in place, but also the incremental exposure being created and how a proposed mitigation changes it.

In an operational change, it can mean looking beyond technical readiness to understand dependencies, concentration across critical services and potential effects on customers.

In third-party management, it can mean moving beyond a static tier and estimating what a supplier failure could mean for the processes and customers that rely on that service.

This is where we pursue smart efficiency becomes especially important. Better risk management is not about creating more reports or additional bureaucracy. It is about directing attention and resources to the exposures that matter most, so teams can act with speed and focus.

In this context, challenging the status quo means changing the question from “Was the requirement met?” to “Are we making the best possible decision for our customers and the resilience of the business?”

A challenge for people who want to build

NFR Brain brings together the kind of problem that motivates us at Nubank: transforming something complex, fragmented and historically reactive into a solution that makes risk visible while there is still time to act.

It requires curious people with technical depth and the willingness to work across disciplines: data professionals who want to solve real business problems; engineers interested in building reliable, scalable platforms; risk specialists who want to use evidence to challenge assumptions; and product-minded people who see clarity and simplicity as part of the experience of decision-making.

We believe the future of risk management is not about producing more reports. It is about building systems that make risks more visible, more understandable and more actionable.

That is what we are building at Nubank.

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