One of the world’s leading providers of payments infrastructure and messaging, launched a KYC Utility – the KYC Registry – initially for Correspondent Banks in 2015. Beyond were asked to conduct a review of the existing policy (“the baseline”) against regulatory requirements and support a number of critical initiatives in enhancing the baseline.

The “baseline” for the KYC Registry had evolved over the four years since launch, and it now contained over 600 questions. Our client wanted to streamline the questionnaire but was not clear on how the questions aligned to regulatory requirements and whether they were required or could potentially be removed.

Equally, the KYC Registry was being expanded to Corporates and Non-Banking Financial Institutions and they wanted to ensure that these new policies were aligned to regulation and the existing Correspondent Banking “baseline”.

Furthermore, there was a desire to expand the “baseline” question set beyond KYC to include Sanctions and Sustainability questionnaires.

Firstly, our team established a clear view on the baseline questions and consolidated all requests for changes. This baseline was then reviewed and mapped against regulatory requirements, including key implementation guidance documents, and any gaps were highlighted.

The Beyond team engaged the KYC Registry User Group – a group of compliance and operations representatives from over 18 global banks – to refine the baseline and implement changes. This included re-designing the User Group governance process for managing changes to the baseline.

As part of this work, we also worked closely with the Wolfsberg Group, making recommendations for changes to the Correspondent Banking Due Diligence Questionnaire (CBDDQ), an industry standard template.

Our team then collaborated with the internal KYC Registry teams – including operations and technology – to implement these changes to the policy, procedures and ultimately the core technology platform.

We also supported the expansion of the baseline for the Sustainability questionnaire by working closely with the International Chamber of Commerce (ICC), helping to develop an industry standard questionnaire that would help financial services enhance their sustainability approaches.

Beyond played a critical role within this project, not only ensuring that the existing policy aligned with regulatory requirements but also helping further evolve the baseline to support critical initiatives. This included a regulatory mapping exercise, the development of a new Sustainability questionnaire, and a number of improvements to the baseline to improve usability, structure and usefulness.

We were very quick to build strong engagement with 18 User Group banks through our regular group and 1:1 meetings, which provided a forum to propose, discuss and agree policy updates. These relationships – plus those in the internal technology, operations and policy teams – helped secure the buy-in needed to make the changes required to the baseline.