Project Description

Set up a compliant onboarding process

Due to stricter guidelines from De Nederlandsche Bank (DNB), a large financial service provider is forced to reorganize the customer onboarding process. Enigma Consulting fulfilled the role of “product owner” in the redesign. This case describes the reason for the assignment, the approach and the result.


Verifying the identity of a private customer is about establishing that the specified identity matches the real identity. DNB has indicated in the ‘Guidelines Wwft 2019’ that institutions must use one or more other reliable and independent sources in addition to an identification deposit to verify the identity of the customer. For example: a copy of the passport uploaded by the customer is insufficiently reliable, because a fraudster can easily abuse it. A scan of the passport via the mobile phone and a digital check that the person is alive does comply with the rules.

The new regulations apply retroactively. This means that this financial player must re-onboard all customers from 1 July 2018. In addition, the onboarding for all new customers will take place via the newly set up process from 1 January 2021.

Approach and result

Enigma’s consultants are responsible for facilitating, organizing and implementing the new process, so that the responsible business units can execute these processes compliantly. This process consists of two parts:

  1. Remediation: verification of the identity of existing customers who became customers after July 2018. Remediation means that the quality of the previous onboarding process is increased to comply with the latest standards and requirements.
  2. Onboard new customers through a compliant process that meets the new guidelines. The goal is to redirect customers from the existing onboarding process to the new identification and verification functionality in the mobile app.

The financial services provider did not have the technology for online identification and verification. Enigma Consulting has been involved in a selection process with eight different specialized parties. The providers have been assessed on security, UX, technology, commerce and references. Ultimately, the process resulted in a single identity and verification solution provider. This provider has the right solution for this company to perform a passport scan (NFC and OCR), followed by a liveliness check. As a result, the financial services provider can 1) offer new customers a compliant (re-) onboarding and 2) existing customers can share additional information to meet the stricter DNB onboarding requirements.

Bas Kerpel
Bas Kerpel
Executive Consultant