Development of CRM requirements for Anti-money laundering project

Sector: Payment Sevices
Area of expertise: Digitalization
Service area: 
Executing Projects


Following a change of legislation and an audit from financial supervisory authority (FSA), the client was required to change their anti-money laundering (AML) processes. The new legislation required the client to; (1) collect Know Your Customer (KYC) information, such as picture IDs, and (2) risk assess all active merchants based on new parameters. To fulfil the two outlined tasks as well as ensure compliance with the new requirements, the IT infrastructure had to be modified and expanded. Kopenhagen Konsulting (KK) was hired to support the continued progress and development to ensure that deadlines were met.


The project was split into a Back Book and a Front Book track, which respectively focused on legacy customers and onboarding of new customers.

In the Back Book track, KK was in charge of three main deliveries:

  1. Define requirements for a new role in the client Customer relationship management (CRM) system
  2. Develop a new project database
  3. Analyse the data
    First, the role in CRM was created to support handling of AML processes for 300 FTEs without interfering with the customer service and sales agents. To create the role, end-to-end processes were designed and used to develop the technical requirements and work instructions for the FTEs. Second, a database was created to keep an overview of all Back Book merchants. The database was generated by merging both internal and external data sources, which created an overview of the project progress. Third, the database allowed for several data analysis, which KK used to reduce the number of required FTEs with around 50%. The reduction was achieved by grouping the data and specifying groups of data outside the AML processes.

In the Front Book track, KK was mainly responsible for one delivery:

  1. Define AML requirements and translate them into CRM user stories

To fulfill the delivery, a new module was designed to create an efficient onboarding flow, while minimizing the additional obstacles for the customers. In the process, requirements from multiple stakeholders were collected, verified, and prioritized to ensure the best possible solution.


As a result, the client was on track with the collection of AML information to reach the FSA deadline. Thus, the client was on schedule to keep their license to operate and avoid paying punitive damages. In the process, the number of FTEs required was reduced by around 50% compared to early estimates. Lastly, the client successfully built a sustainable solution that automizes the future AML processes, which saves the client substantial resources in the future, while only having limited impact on operations.