Risk & Compliance Case

Setting up a compliant onboarding process  

The challenge

  • Major financial services provider required restructuring of customer onboarding due to DNB guidelines
  • Need to verify customer identities using reliable and independent sources
  • Retroactive re-onboarding of customers since July 2018 and new onboarding process from January 2021

Our approach

  • Projective Group acted as the ‘Product Owner’ in the redesign
  • Facilitated, configured, and implemented the new onboarding process
  • Remediation for existing customers post-July 2018, and compliant onboarding for new customers
  • Evaluated and selected an independent identity and verification solution provider through a comprehensive selection process

Key results

  • Existing customers could meet tightened DNB requirements by providing additional information
  • Successful transition from existing onboarding to new identification and verification functionality within the mobile app
Date:May 2, 2022

Due to tightened guidelines from the central bank of the Netherlands (De Nederlandsche Bank, DNB), a major financial services provider needed to restructure its customer onboarding process. Projective Group played the role of ‘Product Owner’ in this redesign. This case outlines the assignment’s background, approach, and outcomes. 


Verifying the identity of a retail customer involves confirming that the provided identity matches the real identity. DNB’s “Leidraad Wwft 2019” stipulates that institutions must use one or more reliable and independent sources, in addition to identification documents, to verify a customer’s identity. For example, an uploaded copy of a passport by the customer alone is not sufficiently reliable, as it can be easily exploited by fraudsters. A passport scan via a mobile phone and a digital check to verify the person’s existence does comply with the rules. 

The new regulations have retroactive effect, meaning that this financial institution needs to re-onboard all customers since July 1, 2018. Additionally, the onboarding process for all new customers from January 1, 2021, takes place through the newly established process. 

Approach and outcome 

Our consultants were responsible for facilitating, configuring, and implementing the new process, enabling the responsible business units to perform these processes in compliance.  

Essentially, this process consists of two components: 

  1. Remediation: Checking the identity of existing customers who became customers after July 2018. Remediation involves improving the quality of the earlier onboarding process to meet the latest standards and requirements. 
  2. Onboarding new customers via a compliant process that adheres to the new guidelines. The objective is to guide customers from the existing onboarding process to the new identification and verification functionality within the mobile app. 

The financial services provider did not have the technology for online identification and verification in-house. Projective Group was involved in a selection process with eight specialised providers. The providers were evaluated based on security, user experience (UX), technology, commercial aspects, and references. 

Ultimately, this process led to the selection of a single identity and verification solution provider. This provider offered a solution that allowed the company to perform a passport scan (NFC and OCR) followed by a liveliness check. This enabled the financial services provider to 1) offer new customers a compliant re-onboarding process and 2) allow existing customers to provide additional information to meet the tightened DNB onboarding requirements. 

Need help setting up a compliant onboarding process yourself? Read more about our AML/CFT support or get in touch with our specialised consultants.

About Projective Group

Established in 2006, Projective Group is a leading Financial Services change specialist. With deep expertise across practices in Data, Payments, Transformation and Risk & Compliance.

We are recognised within the industry as a complete solutions provider, partnering with clients in Financial Services to provide resolutions that are both holistic and pragmatic.  We have evolved to become a trusted partner for companies that want to thrive and prosper in an ever-changing Financial Services landscape.