Case study

KYC remediation and control redesign for a Nordic asset finance business

Matthew N
Co-Founder and PartnerMatthew Neill
Co-Founder and PartnerMatthew Neill

In 16 weeks, BeyondFS helped a Nordic asset finance business design and mobilise a proportionate KYC model, allowing it to keep trading while it remediated customer files and closed the regulatory findings against it.

At a glance
  • Trigger: Urgent regulatory findings on financial crime controls
  • Timeframe: 16 weeks to a credible path to compliance
  • Industry segment

    Nordic Banking Group

  • Function

    KYC Remediation & Control Design

  • Core capabilities

    Event Driven KYC Design, Governance

Key outcomes delivered
  • A leasing-specific trigger catalogue
  • Documented review procedures and prioritised requirements
  • Clear governance and escalation routes
  • Frontline guidance
  • Written rationales for controls that didn't apply to the business model
  • Onboarding and event-driven KYC minimum viable product live within the deadline, with a reusable approach for every Nordic market the business operates in. 

The Challenge

Group-level controls had been designed for high-volume payments, not for leasing customers.

The business had received urgent regulatory findings on its financial crime controls across lending and leasing. It had two problems to solve at once: remediate the customer files that were already defective, and stop new weaknesses entering through the onboarding pipeline.

The business model made this harder. Group-level controls had been designed for high-volume payments, not for leasing customers. So before anything could be fixed, the bank had to separate genuine control gaps from requirements that simply didn't reflect its products or risks, and it needed clear evidence to support each of those decisions.

The stakes were high. With the viability of some business lines under review, a credible path to compliance had to be mobilised within 16 weeks.

what we did

We defined what had to be delivered first

We helped the client shape a practical minimum viable product for onboarding and event-driven KYC. Requirements from KYC, Legal, Risk Data and Tooling were consolidated and prioritised, which made it clear what had to land inside the regulatory window and what could move into a controlled second phase.

Reviewed event-driven KYC for leasing 

We assessed the bank's enterprise trigger catalogue against the leasing environment. That meant identifying which events were relevant, and highlighting triggers that were already happening but weren't being consistently recognised by frontline teams.

Documented the response to every trigger

For each applicable trigger, we set out the due diligence required, the roles involved, timelines, evidence and the escalation route. Where standard transaction-pattern triggers didn't fit a leasing model, we wrote a risk-based rationale for excluding them, so the decision could be defended later.

Put governance around the decisions

We brought KYC, Legal, Risk and technology stakeholders together in a cross-functional forum to assess options, record decisions and agree a roadmap for replacing temporary measures with a more scalable design.

the Outcome

The onboarding and event-driven KYC minimum viable product had been designed and mobilised.

The business could keep operating while remediation progressed, which reduced the risk of regulatory fines or restrictions.

The client was left with:

  • a leasing-specific trigger catalogue
  • documented review procedures and prioritised requirements
  • clear governance and escalation routes
  • frontline guidance
  • written rationales for controls that didn't apply to the business model

Together, these gave the business a defensible basis for proportionality, and a repeatable approach it can apply across every Nordic market it operates in. A second-phase roadmap sets out how the initial solution becomes more efficient and scalable over time.