Compliance/KYC reporting for a major Swiss bank
We found recurring audit findings tied to incomplete KYC files in private banking: missing or outdated IDs, weak source-of-wealth narratives, inconsistent beneficial owner declarations, and ad-hoc review cycles. Onboarding stalled, periodic reviews slipped, and exceptions piled up because teams relied on manual checklists and emails without a single source of truth.
We built a file-completeness blueprint aligned to FINMA and SBA standards, standardised templates for Form A and source-of-wealth, and a risk-based review cadence. We embedded these into workflow, added automated PEP/sanctions checks, and a dashboard that showed file status by relationship, risk tier, and ageing. Within one quarter, legacy gaps were remediated, audits closed with no material findings, onboarding became predictable, and relationship managers had clear accountability for keeping files complete.
Approach
- 1
Map gaps and owners against FINMA and SBA expectations
- 2
Standardise Form A and source-of-wealth templates
- 3
Set risk-based review cadence with clear triggers
- 4
Automate PEP and sanctions checks inside workflow
- 5
Build file status dashboards by relationship and ageing
- 6
Assign accountability and simple SLAs to keep files complete
Takeaways
- Completeness rules must be explicit and embedded in the workflow
- Automate the nudge and evidence, not the judgement
- Dashboards that show ageing by risk tier drive the right action
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Case: swiss-bank-kyc