Contact us
Contact us
Case study

Ensuring a compliant and cost-effective customer migration for a major European bank​

Al Catto
Lead partnerAl Catto
Lead partnerAl Catto

A major European bank faced a complex and operational challenge as it prepared to migrate a large customer base to a new provider. The process was governed by strict compliance requirements, with an independent quality assurance review mandated to ensure regulatory standards were met. Any discrepancies in customer records could have resulted in financial penalties and costly remediation efforts.

  • Industry segment

    European Bank

  • Function

    Client Migration

  • Core capabilities

    KYC / CLM

Key outcomes delivered
  • 240,000 customers successfully migrated, while fully meeting strict compliance requirements.
  • £10 million contingency saved, as no additional KYC remediation was needed.
  • Zero regulatory breaches – all compliance issues were identified and addressed successfully.

Results

Migration

0

customers migrated to their new banking provider.

Cost savings

£0 million

contingency saved, as no additional KYC remediation was needed.

Regulatory

0 breaches

No regulatory breaches as all issues were identified and addressed.

Challenge

Helping a major European bank achieve a smooth and compliant customer migration

Our client, a major European bank, had made the decision to divest a portion of its customer base to another personal and private banking business. A seamless migration was critical, not just from an operational standpoint, but to meet strict compliance obligations outlined in an Asset Purchase Agreement (APA).

The agreement required a robust third-party assurance process to verify that all customers being transferred met Know Your Customer (KYC) requirements. A Big 4 firm had been deployed to implement a rigorous quality assurance framework.

With over 250,000 customers in scope and complex due diligence requirements, the bank faced several key challenges:

  • Regulatory risk – The APA mandated that KYC files be fully compliant before migration. Any gaps in customer records or due diligence could result in regulatory scrutiny and financial penalties. 
  • Operational complexity – The scale of the migration required a structured approach to reviewing and assuring 160,000 Ongoing Due Diligence (ODD) cases, without overwhelming the internal team. 
  • Financial exposure – If the bank failed to meet the APA’s requirements, it would need to spend up to £10 million on additional KYC remediation, significantly increasing the cost of the divestment.

With high stakes and a tight timeline, the bank needed a clear, controlled, and collaborative approach to customer migration. 

Approach

Designing a scalable migration process

  • BeyondFS was engaged to help the bank deliver a smooth, compliant customer migration while meeting the strict requirements set out in the Asset Purchase Agreement (APA). Our role was to support the internal team with our KYC expertise, strengthen quality controls, and foster collaboration across key stakeholders.
  • We started by ensuring the bank’s internal team had the right structure, processes, and capacity to manage the Ongoing Due Diligence (ODD) workload. With 160,000 customer files requiring review, we helped scale operations and put robust oversight in place.
  • To ensure compliance, we worked with a Big 4 firm that had been put in place to handle quality assurance processes. We were trusted to supervise 40 staff from the Big 4 firm to ensure good communication and a high throughput. High-risk cases were reviewed in full, while medium- and low-risk files were statistically sampled to verify adherence to regulatory standards. 
  • Where gaps were identified, we worked closely with the bank to address both critical regulatory gaps and operational issues and inefficiencies, preventing these from becoming roadblocks to migration.
  • Collaboration was key to success. We aligned compliance, operations, and technology teams to ensure a joined-up approach, fostering a culture of shared responsibility for KYC requirements.
  • Throughout the engagement, we provided weekly progress reports, giving stakeholders clear visibility into file quality, emerging issues, and overall progress.
BFS-services-4
Outcome

A successfully smooth customer migration

The migration was successfully completed, with 240,000 customers transferred while fully meeting the compliance requirements. Our structured, collaborative approach ensured that all regulatory expectations were met, avoiding unnecessary costs and operational risks.

Our work:

  • Met high compliance standards, saving costs – By ensuring all KYC files met strict standards, the bank avoided any regulatory breaches and successfully completed third-party assurance reviews. This meant the £10 million contingency budget for additional KYC remediation was not required.
  • Created a scalable, well-controlled migration process – With robust oversight, clear accountability, and cross-team collaboration, the bank was able to execute the migration efficiently while maintaining high compliance standards.
  • Strengthened cross-functional collaboration – By working across the teams involved, we helped embed a culture of shared responsibility for KYC, improving coordination across critical functions.