Zenbridge Bank: KYC Operations Transformation
CBN-Licensed Tier-2 Commercial Bank | Lagos, Nigeria
Following a routine CBN Risk-Based Supervision examination, Zenbridge Bank received an “Unsatisfactory” rating on its KYC process controls. The findings were specific: 41% of SME cases had no auditable BVN verification record, NFIU screening was happening after account opening in 28% of cases, and 22% of sampled accounts had no CDD verification trail at all. The bank managed over 1,100 onboarding cases a month entirely through shared email inboxes and three separate Excel trackers. The CBN gave them 60 days to produce a remediation plan and scheduled a follow-up review at Month 7.
CBN Re-Examination Result
Month 7 follow-up: target outcome achieved on schedule
SME SLA Breach Rate
3 months post go-live
Retail Cycle Time
62% reduction
SME Cycle Time
58% reduction
Rework Rate
76% improvement
What I Did
Brought in by the COO office to lead discovery, requirements, solution design, and delivery oversight for a 7-month remediation programme. The solution was built entirely within the bank's existing Microsoft 365 tenant, which kept procurement out of the picture and kept us on schedule for the CBN's deadline.
Ran six shadow sessions with KYC analysts in Lagos and Abuja to document the actual process, not the policy-documented version. This is where we found that analysts were handling Nigerian name formats (Yoruba, Igbo, Hausa) in ways the NFIU screening system did not recognise.
Ran a mock CBN examination walkthrough with the Head of Internal Control before go-live, selecting 10 live case files to test what an examiner would find. This exercise drove the final audit trail architecture design.
Designed six Power Automate flows, including the NFIU pre-approval screening gate (addressing the 28% post-opening finding), the BVN hard gate with audit write-back, and the SLA escalation chain from Team Leader through to the COO daily breach digest.
Built the Nigerian KYC Document Requirements Matrix covering all customer types, including the Business Name vs. Limited Company distinction that was the single biggest driver of SME rework. That one routing rule reduced SME rework from 41% to 7%.
Managed the change programme across 28 KYC analysts and 4 team leaders, training TLs as super users a week ahead of the analyst rollout so they could support their own teams through the transition.
Coordinated a phased 3-day cutover with hypercare, decommissioned 5 shared email inboxes, and supported the bank's CBN submission for the follow-up targeted review.