Support in the implementation of new Customer Identification Data regulation

Client Needs & Objectives


Swiss Private Bank under the authority of the Swiss Financial Market Supervision Authority (FINMA)

Situation before the project:

  • Main stakeholder had been appointed but project was months behind schedule
  • No planning had been performed
  • No workload estimation had been computed
  • No action had concretely been undertaken to meet the new requirements


The Swiss Financial Market Supervision Authority (FINMA) issued a new regulation regarding measures to be taken to protect Customer Identification Data held by Swiss Banks. In this context our client wanted:

  • To obtain support in order to determine what  concrete actions had to be undertaken in order to comply to the new rules
  • To obtain support in order to plan and organize the implementation project

Our approach

  • Obtain a deep understanding of the new regulation
  • Define what concrete requirements resulted from the regulation
  • Determine the sequence in which actions needed to be undertaken to allow proper implementation
  • Determine stakeholders to be involved in the project
  • Compute the workload for each step and each stakeholders
  • Define milestones for each step
  • Organize regular follow-up meetings and Steering Committee

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