Banking onboarding and compliance / Track record

Automating international account opening.

Automate the path from international customer evidence to a correctly created bank account, with institutional risk decisions inside the workflow.

A rules-based onboarding workflow with identity verification, risk escalation, electronic signing and an encrypted bank-account interface.

Applicant documents move through a row of glass checkpoints for review, scoring and signature, with rejections diverted, before reaching a secure bank vault.
Contents
Delivered by
PIB Technology Limited.

Responsibility

Carlos Molina

Carlos Molina led the program: Board Chair of the bank from 2018; Founder and CEO of PIB Technology from 2019.

Set program priorities and commercial terms with the bank's governance, and directed the delivery team and suppliers. Customer-risk decisions, bank acceptance and outsourcing review stayed with the responsible bank functions, its Board and the regulator.

Set the ownership, portability and banking-interface requirements, led supplier and governance work, and challenged test coverage and delivery readiness. An integration adviser coordinated technical completion; supplier engineers developed and integrated their components.

PIB Technology delivered OBA, an automated international account-opening workflow, to a private bank. Opening an account across borders requires identity, residence, ownership, source-of-wealth and expected-activity evidence that supports the bank's decision to take the client. The bank needed that evidence collected, checked and routed to the right reviewer, and the approved client created in its existing core banking platform. The first scope covered individual customers entering a digital-asset-related banking service.

OBA joined a customer-facing application to the bank's due-diligence process and existing account model. The design automated the eligible path, routed elevated risk to authorized reviewers and exchanged encrypted account requests and results across an organizational boundary. PIB Technology coordinated application developers, a banking-platform supplier, an integration adviser, external control advisers and the bank's operations, compliance, risk and finance functions.

01 / The problem

The invariant: a complete application must become a valid bank record

The front end had to collect the information required by due diligence and by the bank's account model. Nationality, residence, account-holder identity, ownership and expected financial activity influenced both risk review and the records being created. An application could pass a document check and still require additional source-of-wealth evidence, review of a screening hit or institutional approval.

International onboarding moved between the applicant, relationship staff, compliance, senior risk decision makers and bank operations, and the file had to stay consistent across those handoffs. The goal was a fully automated route for eligible applications, with the bank's exception decisions inside the same process.

The first banking interface covered individual account opening. Phase-two specifications added broader account authorities, flexible KYC questionnaires, duplicate handling and long-term archive integration.

02 / Inside the system

An application boundary, an institutional boundary and a banking boundary

The customer application collected evidence and orchestrated verification, screening, risk calculation and signing. Bank compliance and the relevant committees owned exceptional relationship decisions. The approved account-opening data then crossed into the hosted banking environment through a dedicated file interface.

The November 2018 design specified XML protected with GPG and transferred over SFTP. Bank-side transfer and import components, including Zena and a File Transfer Adapter, supported creation of customer, account and e-banking objects. Replies were encrypted before transfer back to onboarding. This request–result exchange gave both sides a concrete boundary to validate.

Document retention followed a separate path. The first design used temporary bank storage. The phase-two specification added a daily archive feed of PDF files with XML metadata, with operations handling archive errors. Account creation and document archival were therefore different states.

Application-to-bank path: customer evidence and controls lead to signing, encrypted XML through SFTP, bank import and account records, with an encrypted result returned and a separate retention branch.
Account results and document retention are separate paths. The daily archive feed belongs to the phase-two specification.Open full diagram ↗
Customer workflow
Rules-based collection, screening, identity verification, risk calculation and electronic signing.
Institutional decisions
Analyst hit review, bank compliance, enhanced due diligence, AML committee and Board escalation.
Banking interface
XML, GPG, dedicated SFTP, transfer/import jobs and encrypted result messages.
Bank records
Customer, account and e-banking objects in the existing core platform.
Retention
Temporary bank storage; daily document-and-metadata archive feed in the phase-two specification.

03 / Inside the system

Workflow design: automate the eligible path, route the exceptions

The process first screened customer information for hits and adverse media. An analyst reviewed hits to distinguish false positives from concerns requiring compliance evaluation. Identity-document and selfie verification followed, before the completed financial and personal information informed a rules-based risk calculation.

Compliance evaluated confirmed screening concerns. High risk, or an escalated concern, triggered enhanced due diligence and AML committee review. Politically exposed persons required a Board decision. Accepted applicants continued to populated forms, electronic signing, pricing assignment and account creation. Rejected applicants received the corresponding notification.

Order of steps: screening and hit review, identity verification, profile and risk calculation, institutional exception decisions, signing, pricing and account request. Confirmed concerns route to compliance; politically exposed persons require Board review.
Rules-based workflow and human exception authority. The institutional decision path precedes signing and account creation where required.Open full diagram ↗

A worked example

An elevated-risk application

Example with invented data.

  1. 01Submit the required evidence

    An international individual supplies identity and address details, a document and financial context. The application gathers the fields required for screening and the bank's account model.

  2. 02Resolve a screening hit

    A screening match goes to analyst review. If it is a false positive, the workflow continues; a confirmed concern is escalated to bank compliance.

  3. 03Verify identity and determine risk

    The document and selfie are checked, and the completed profile informs the rules-based rating. The application is rated elevated risk and needs additional wealth evidence.

  4. 04Obtain the institutional decision

    Compliance conducts enhanced due diligence and presents the case to the AML committee. A politically exposed person follows the Board route. Rejection ends the account-opening path; acceptance allows it to continue.

  5. 05Sign and transmit the account request

    After required approvals and signing, the application prepares an encrypted XML request. SFTP and bank-side import processing carry it into customer, account and e-banking creation.

  6. 06Handle the result and retention separately

    An encrypted account result returns to onboarding. A content or import failure needs repair at its responsible boundary. In the phase-two archive specification, document failures go to operations independently of the account result.

04 / Inside the system

Choose interfaces and controls that match the operating constraints

The application was required to remain portable outside the existing banking outsourcing arrangement. That preserved an independent customer journey while making the bank's data model and interface contract central to delivery. An encrypted file exchange was the integration route.

The phase-two specifications distinguished a blocking validation failure from a possible duplicate person. A suspected duplicate could generate a central-filing issue for investigation while opening a new record. The archive design also assigned repair to operations rather than returning every failure to the onboarding application. These choices made operational ownership a necessary part of the interface.

  1. Decision 01

    Keep the application portable

    Own the customer application independently of the existing banking outsourcing arrangement.

    The original request required client ownership and the ability to continue operating if the core-service arrangement changed.

    Trade-off. Independence required a maintained data contract and explicit responsibility across the application and bank-platform teams.

  2. Decision 02

    Use an encrypted file exchange first

    Transfer GPG-encrypted XML over SFTP, with encrypted results returned to onboarding.

    The supplier design offered an initial integration path into the bank's existing platform.

    Trade-off. Transfer jobs, imports, results and error handling needed coordinated operation.

  3. Decision 03

    Preserve institutional exception authority

    Route confirmed screening concerns and elevated risk through compliance, due diligence and the appropriate committee or Board.

    Risk acceptance depended on the bank's governance as well as verification results.

    Trade-off. Exceptions interrupt the automated path and require a complete evidence package for the authorized reviewer.

  4. Decision 04

    Assign archival recovery to operations

    In the phase-two archive specification, park invalid documents and alert operations without returning an archive failure to onboarding.

    The daily archive import was a separate operational process.

    Trade-off. Successful account creation did not mean successful retention; operations needed to investigate and correct archive errors.

05 / Inside the system

Evaluate the data, the interface and the permission to operate

The supplier test design covered the file chain from transfer and decryption through import, reply generation and return encryption. Negative cases included malformed XML, wrong formats and values outside their allowed domains. Country, residence and currency variations tested behavior that a single successful account opening could miss.

Integrated acceptance used real application-generated files and bank validation of the resulting records. Restricted account opening in the bank's production environment, with funding and payments disabled, then tested the complete journey. The defects and improvement needs it exposed fed back into modifications. Bank acceptance, an independent control assessment and the material-outsourcing review each had their own owner.

Four evaluation responsibilities: supplier file-chain tests, bank data and acceptance review, independent control assessment and regulator review of outsourcing. A restricted account-opening exercise in production tested the whole journey with funding and payments disabled.
Four evaluation responsibilities around one account-opening journey, each with its own owner and acceptance criteria.Open full diagram ↗
Does a valid XML file make a valid customer?
Interface validity is one check. Customer acceptance also depends on identity evidence, screening, risk review and the bank's authorized decision.
Does account creation mean the documents are archived?
No. The phase-two design treats archival as a separate import. Metadata or document failures are parked for operations, without an application failure reply.
Does supplier completion make the system ready to operate?
No. The bank accepts the process, an independent assessor reviews the controls and the regulator reviews outsourcing. Supplier completion covers only the supplier's components.

06 / Inside the system

Give each dependency an owner and a reviewable handoff

Application and banking suppliers owned different components. An integration adviser coordinated completion and the interfaces between them. Bank operations validated mapped records; compliance and risk owned customer escalation and control assessment; finance supported commercial and contract work. External advisers contributed due-diligence and assurance requirements, while the regulator reviewed the relevant outsourcing arrangements.

Steering work connected those functions around delivery readiness. Discussions addressed supplier delays, bank data checking, field combinations and test coverage. A working component, an accepted bank process and authorized routine operation have different decision owners.

The people around the workflow.

Applicant and relationship team
Supply identity, address, financial information and supporting documents.
Application developers and verification services
Implement collection, screening, identity checks, signing and the outbound banking contract.
Bank-platform supplier and integration adviser
Coordinate transfer, import, account objects, results and integrated testing.
Bank operations, compliance, risk and finance
Validate data, resolve exceptions, assess controls and support acceptance and contracts.
Board, external control advisers and regulator
Provide the required risk decisions, assurance work and outsourcing review.

Technology and integrations

Services in the workflow.

JumioIdentity-verification service

Identity-document authenticity and ID-photo/selfie matching in the onboarding workflow.

Identity verification

AvaloqExisting core-banking platform

Existing banking platform; account/e-banking object creation through an encrypted import-and-reply interface.

Core banking platform

KrollScreening analyst service

Analyst validation of screening hits and deeper screening before institutional compliance review.

Screening analyst review

Duff & PhelpsAdvisory service

Due-diligence and control-design advisory work on risk, KYC/AML and consent/storage processes.

Control-design advice

ComplyAdvantageScreening service

Initial sanctions and adverse-media screening with hits routed for review.

Sanctions and adverse-media screening

DocuSignElectronic-signature service

Electronic signing of populated forms and contracts after institutional clearance.

Electronic signing

The design principle

Automation can prepare and connect the evidence; risk acceptance remains with the institution. The controls travel with the customer journey.

Carlos Molina / Track record

Earlier systems.
Current work.

Delivered by PIB Technology Limited. Read the career behind this work, or see the systems Embedding Labs builds today.